Scope and Application
This Privacy Policy outlines how Erasmus Student Network Belgium vzw (hereinafter referred to as “ESN Belgium”, “we”, “us”, or “our”) processes personal data obtained through its official website (esnbelgium.org), associated subdomains, electronic contact forms, and digital communication channels.
This policy applies to all prospective exchange students, current students, alumni, institutional partners, volunteers, and external stakeholders whose personal data is processed by the national organisation.
Identification of the Data Controller
Under Article 4(7) of Regulation (EU) 2016/679, the legal entity acting as the Data Controller is:
Erasmus Student Network Belgium vzw (ASBL)
Enterprise Number (BCE / Crossroads Bank for Enterprises): BE 0563.913.161
RPM / Legal District: Walloon Brabant (Nivelles)
Registered Seat: Rue Haroun Tazieff 1, 1348 Louvain-la-Neuve, Belgium
Official Contact Email: board@esnbelgium.org
For all inquiries concerning data protection, GDPR compliance, or the exercise of statutory data subject rights, requests should be directed in writing to the national administrative address or submitted electronically to board@esnbelgium.org.
Core Data Protection Principles
In accordance with Article 5 of the GDPR, ESN Belgium adheres strictly to the following fundamental principles throughout all data handling procedures:
- Lawfulness, Fairness, and Transparency: Personal data is collected and processed with explicit legal grounds and in a transparent manner.
- Purpose Limitation: Data is acquired exclusively for declared, explicit, and legitimate purposes and is not further processed in a manner incompatible with those aims.
- Data Minimisation: We gather only the minimal volume of personal information strictly required to achieve the intended operational objective.
- Accuracy: Reasonable steps are maintained to guarantee that records are kept up to date and rectified without delay when inaccuracies arise.
- Storage Limitation: Personal identification data is retained only for the duration necessary to satisfy operational or legal mandates.
- Integrity and Confidentiality: Technical safeguards prevent unauthorised alteration, unlawful processing, accidental destruction, and security compromise.
Categories of Data & Processing Operations
Depending on your interaction with this platform, ESN Belgium processes the following distinct categories of information:
| Processing Activity | Data Categories | Primary Purpose | Legal Basis (GDPR) |
|---|---|---|---|
| Server Operation & Security | Internet Protocol (IP) address, timestamp, requested URI, HTTP status code, browser type, and operating system string. | Ensuring network availability, server integrity, intrusion mitigation, and DDoS prevention. | Art. 6(1)(f) — Legitimate Interest |
| General & Partnership Inquiries | Full legal name, professional/personal email address, inquiry classification, subject heading, and free-text message. | Routing inquiries to the appropriate national coordinator and processing correspondence. | Art. 6(1)(a) — Explicit Consent |
| Local Client Preferences | Interface language selection token (stored purely within local browser storage). | Persisting interface usability across visits without establishing user identification. | Art. 6(1)(f) — Legitimate Interest |
| Statutory Association Governance | Official correspondence records, board resolutions, and partner cooperation agreements. | Compliance with Belgian non-profit association statutory bookkeeping and accountability rules. | Art. 6(1)(c) — Legal Obligation |
Technical Privacy & Self-Hosted Assets
ESN Belgium enforces a strict Privacy by Design and by Default standard across its web engineering stack:
5.1 Self-Hosted Typography (Google Fonts Elimination)
To prevent unmonitored transmissions of IP addresses and device headers to external multi-national technology corporations, this website does not connect to external third-party font delivery networks (such as fonts.googleapis.com or fonts.gstatic.com). All font binaries (Inter and Plus Jakarta Sans) are downloaded, version-locked, and served strictly from our local Belgian web server directory (/assets/fonts/).
5.2 Complete Absence of Third-Party Trackers & Analytics
This platform does not deploy Google Analytics, Google Tag Manager, Meta (Facebook) Pixels, LinkedIn Insight Tags, hotjar tracking scripts, or behavioural surveillance mechanisms. No cross-site fingerprinting or automated profiling algorithms are active.
5.3 Cookies & Client-Side Storage
This platform does not issue non-essential tracking, advertising, or profiling HTTP cookies. Browser local storage (localStorage) is used exclusively for stateless functional settings (such as retaining the selected viewing language: EN, NL, FR, or DE). This utility data contains zero identifiable metrics and does not track users outside the scope of this website.
Legal Grounds for Processing (GDPR Art. 6)
Every processing operation executed by ESN Belgium relies upon an established statutory ground defined in Article 6(1) of the General Data Protection Regulation:
- Consent (Art. 6(1)(a) GDPR): Applicable when users voluntarily submit communications via the electronic contact form and tick the mandatory pre-submission consent acknowledgement.
- Performance of a Contract (Art. 6(1)(b) GDPR): Applicable where processing is necessary to prepare, enter into, or execute a formal partnership agreement, sponsorship arrangement, or membership contract.
- Compliance with Legal Obligations (Art. 6(1)(c) GDPR): Applicable to records retained to satisfy Belgian non-profit association statutory filings, tax reporting, and audit requirements.
- Legitimate Interests (Art. 6(1)(f) GDPR): Applicable to the retention of temporary server diagnostic logs necessary to guarantee web security, resist malicious cyber attacks, and maintain service continuity.
Data Retention Schedule
In compliance with the principle of storage limitation, personal records are purged or anonymised according to predefined schedules:
| Data Category | Retention Period | Justification |
|---|---|---|
| Server Access & Error Logs | Maximum 30 calendar days | Short-term network defense, debugging, and intrusion tracking. |
| Contact Form Submissions | Up to 12 months following inquiry closure | Ensuring resolution continuity, service verification, and follow-up support. |
| Partnership Agreements & Invoices | 7 to 10 years | Belgian corporate, accounting, and tax compliance legislation. |
Technical & Organisational Security
ESN Belgium implements standard technical and administrative safeguards to protect records against unauthorised access, alteration, disclosure, or accidental erasure:
- Transport Layer Encryption (TLS / HTTPS): All communications between your web client and our hosting environment are encrypted using standard TLS protocol suites.
- Role-Based Access Controls: Access to contact records and internal systems is restricted strictly to designated National Board members and Coordinators on a documented need-to-know basis.
- Routine Infrastructure Patching: Operating system kernels, web daemon components, and cryptographic libraries undergo regular security updates.
Third-Party Disclosure & Location of Servers
ESN Belgium does not sell, lease, monetise, or distribute personal data to commercial third parties, ad networks, or data aggregators.
All primary web servers and storage volumes utilised for this website are physically hosted within data centres situated in the European Union / European Economic Area (EEA). No data transfers to non-adequate third countries (as defined under Chapter V of the GDPR) occur in connection with ordinary website browsing.
Rights of the Data Subject
Under Chapters III and VIII of the General Data Protection Regulation, individuals located within the European Union retain the following statutory prerogatives:
- Right of Access (Art. 15 GDPR): The right to obtain confirmation as to whether personal data concerning you is being processed and to receive a copy of that data.
- Right to Rectification (Art. 16 GDPR): The right to obtain without undue delay the correction of inaccurate or incomplete personal records.
- Right to Erasure / “Right to Be Forgotten” (Art. 17 GDPR): The right to obtain the erasure of your personal data where retention is no longer justified under law.
- Right to Restriction of Processing (Art. 18 GDPR): The right to restrict the scope of processing under specific contestation periods.
- Right to Data Portability (Art. 20 GDPR): The right to receive provided personal data in a structured, commonly used, and machine-readable format.
- Right to Object (Art. 21 GDPR): The right to object at any time to processing based on legitimate interests.
- Right to Withdraw Consent (Art. 7(3) GDPR): Where processing is anchored upon consent, you retain the unencumbered right to withdraw consent at any time without compromising the legality of prior processing.
Procedure for Exercising Rights
To submit a formal request regarding any of the rights enumerated in Section 10, please transmit a signed written request or send an email to:
Erasmus Student Network Belgium vzw — Data Protection Portfolio
Email: board@esnbelgium.org
In accordance with Article 12(3) of the GDPR, requests will be processed and addressed free of charge within one calendar month of receipt. If an inquiry demonstrates exceptional complexity or volume, this response window may be extended by up to two additional months, accompanied by formal notice.
Supervisory Authority & Complaint Mechanism
Without prejudice to any other administrative or judicial remedy, every data subject possesses the right to lodge a formal complaint with the competent national supervisory authority if they consider that the processing of personal data relating to them infringes European or Belgian data protection regulations.
Autorité de protection des données / Gegevensbeschermingsautoriteit
Address: Rue de la Presse 35, 1000 Brussels, Belgium
Telephone: +32 (0)2 274 48 00
Email: contact@apd-gba.be
Official Website: https://www.dataprotectionauthority.be
Policy Revisions
ESN Belgium reserves the right to amend this Privacy Policy periodically to reflect technological evolutions, legal revisions, or operational changes within the network. Any substantive updates will be documented on this page with an updated statutory effective date.
Document Version 2.1 • Released in Brussels & Louvain-la-Neuve, Kingdom of Belgium