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Privacy Policy

Last Updated:

Cueca ASBL ("we," "our," or "us") operates https://cueca.eu (the "Site"). We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your data when you visit our Site, submit a contact form, or subscribe to our newsletter.

Under the General Data Protection Regulation (GDPR), we act as the Data Controller for the personal information you provide to us.

1. Data We Collect and Why We Collect It

We only collect data that you voluntarily provide to us, or basic technical metadata required to keep our website running securely and efficiently.

A. Contact Form Submissions

  • Data Collected: Name, email address, and any personal information you choose to include in your message box.
  • Legal Basis for Processing: Legitimate Interest (GDPR Article 6(1)(f)). We process this data solely to respond to your specific inquiries and support requests.
  • Service Provider and Recipient: Mailgun, a Sinch Email service, processes your name, email address, and message through its EU service region solely to deliver your inquiry to us.
  • Data Retention: We keep contact form messages only as long as necessary to fulfill your request or maintain the ongoing business conversation.

B. Newsletter Subscriptions

  • Data Collected: Email address.
  • Legal Basis for Processing: Explicit Consent (GDPR Article 6(1)(a)). You must actively check an un-ticked box and confirm your subscription via a confirmation email (Double Opt-In) to join.
  • Service Provider and Recipient: Kit processes and stores your email address to manage double opt-in, maintain our subscriber list, and deliver the newsletter.
  • Data Retention: We retain your email address until you choose to opt out. You can click the "Unsubscribe" link at the bottom of any newsletter to immediately remove your data.

C. Website Performance & Analytics (Vercel)

  • Data Collected: Fully anonymized technical metrics (e.g., page loading times, browser type, operating system, country location, and visited page paths).
  • Cookie Usage: Zero. This tracking uses no cookies, stores no persistent identifiers, and does not track you across other websites. Your raw IP address is stripped and anonymized immediately upon network ingestion.
  • Legal Basis for Processing: Legitimate Interest (GDPR Article 6(1)(f)). We monitor website speed and user-experience trends to maintain site security and stability.

D. Editorial Content Management & Delivery (Sanity)

  • Data Collected: Basic technical connection metadata, including your IP address, access time, browser type, and operating system, when your browser requests content or live content updates.
  • Purpose and Recipient: Sanity provides our editorial content management and content-delivery platform. It processes this data to deliver current Site content and protect the service against abuse. We do not use Sanity for advertising or user profiling.
  • Legal Basis for Processing: Legitimate Interest (GDPR Article 6(1)(f)). We use Sanity to manage and securely publish current Site content.
  • Data Retention: Sanity states that it deletes or anonymizes access logs within 90 days.

2. Third-Party Content & Dynamic Elements

To safeguard your privacy on our site, we prevent third-party companies from tracking your browsing habits upon page load.

Two-Click Gated External Content (YouTube and Google Maps)

We do not load YouTube videos or Google Maps by default. External content remains locked behind a same-origin placeholder unless you approve the individual asset, temporarily load all external content on the current page, or have a valid remembered approval for that service.

  • With no remembered approval, loading one of our pages does not contact YouTube or Google Maps. Clicking "Play" or "Load Content" approves only that specific asset for the current page view.
  • After you load an asset, we may offer to load every blocked external asset on the current page. This page-wide choice is temporary and ends when you refresh or leave the page.
  • Selecting "Let Me Choose Each Time" disables these page-wide suggestions across the Site but does not approve any external content. Individual gates remain available, and you can re-enable suggestions through "External Content Settings" in the footer. This interface preference remains until you change it.
  • You may separately choose to always allow each listed service for 6 months. The checkboxes are unticked by default, and approval for one service never authorizes another service or any future provider.
  • Remembered approvals and the page-wide suggestion preference are stored only in your browser under cueca:external-content-consent:v1. For each approved service, the record contains the time approval was given and its non-renewing expiry time; the suggestion preference contains no provider approval and remains until you change it. The Site reads these first-party preferences on later visits and automatically loads content only from services with an unexpired approval.
  • Once external content loads, that service may place cookies or track your interaction according to its independent privacy rules.
  • You can enable or disable page-wide suggestions and review or withdraw remembered approvals at any time through "External Content Settings" in the footer. Withdrawal immediately blocks and unloads that service’s content on the current page and prevents automatic loading on later pages. It cannot delete cookies the external service has already stored; you can remove those through your browser settings.

3. Data Storage, Security, and Transfers

  • Hosting & Telemetry: Our website is hosted on Vercel infrastructure. Technical performance metadata may be processed globally.
  • International Transfers: Vercel, Kit, and Sanity may process personal data outside the European Economic Area (EEA). Where required, transfers are protected by an applicable adequacy mechanism, such as the EU-U.S. Data Privacy Framework, or by Standard Contractual Clauses under the relevant provider's Data Processing Agreement. Mailgun processes contact-form data through its EU service region. You may contact us for more information about or a copy of the relevant safeguards.
  • Data Security: We use industry-standard Transport Layer Security (HTTPS/TLS) encryption to protect your data during submission through our contact and newsletter forms.
  • No Data Selling: We never sell, rent, or trade your personal data to third parties for marketing purposes.

4. Your Rights Under the GDPR

Under the GDPR, you hold the following statutory rights regarding your data:

  • Right to Access: You can ask for a copy of the personal data we hold about you.
  • Right to Rectification: You can request that we correct inaccurate or incomplete information.
  • Right to Erasure ("Right to be Forgotten"): You can request that we delete your email or form history from our systems.
  • Right to Restriction of Processing: You can ask us to restrict the processing of your personal data where the law provides this right.
  • Right to Object: You can object to processing based on our legitimate interests.
  • Right to Data Portability: You can request personal data you provided to us in a structured, commonly used, machine-readable format where this right applies.
  • Right to Withdraw Consent: You can cancel your newsletter subscription at any time. You can also withdraw remembered external-content approvals and manage page-wide suggestions through "External Content Settings" in the footer.
  • Right to Lodge a Complaint: You can lodge a complaint with the Belgian Data Protection Authority or another competent data protection supervisory authority.

To exercise any of these rights, please contact us directly using the details provided below.

5. Contact Information

For any questions regarding this Privacy Policy or your data, you can reach us at:

  • Email: cueca.euro@gmail.com
  • Mailing Address: 157 Rue de l'Hospice Communal, 1170 Watermael-Boitsfort, Bruxelles, Belgium.