STEP - Privacy Policy

Terms Used in This Privacy Policy

In this Privacy Policy, we use the terms:

• "we," "us," and "our" (and other similar terms) to refer to VO GROUP SA, a company incorporated under the laws of Belgium with registered office at 1000 Brussels, Rue Haute 139 and registered with the CBE under number 0898 188 425;
• "personal data" to refer to any information relating to an identified or identifiable natural person;
• "you" and "your" (and other similar terms) to refer to the users of the Platform;
• "Platform" to refer to the STEP web platform for which VO GROUP is providing the services; other terms have the meanings set out in the applicable data protection laws (in particular the General Data Protection Regulation (EU) 2016/679).

Who is responsible for your personal data?

VO GROUP (BCE/KBO 0898 188 425) is the data controller responsible for your personal data. Our contact details are provided below.

What personal data do we collect and process?

We collect and process the following personal data from you:

• Identity and Contact Data, including your name, e-mail address, country, job title, and function;
• Registration Data, including the STEP activities you register for (workshops and/or online training);
• Technical Data, including information collected during your visits to the Platform, the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, and operating system.

If you provide us with information about a third party, you must ensure that the third party is aware of how the data will be used and has authorized you to disclose it to us for use (this authorization also applies to our outsourced service providers). If we need personal data from people related to you to respond to your request, we ask that you bring this document to their attention.

How do we collect your personal data?

In most cases, we will collect personal data:

• when you register for STEP activities through the Platform; or
• if you sign up to receive our communications.

The circumstances in which we can collect personal data about you are the following:

• when you register for a STEP workshop, event pilot or online training;
• when you use any of the services of the Platform;
• when you correspond with us by phone, email, or other electronic means, or in writing, or when you provide other information directly to us;
• when you sign up to receive information from us.

How will we use your personal data and on what basis?

We endeavor to process your personal data as appropriately as possible, limiting its use to what we deem reasonably necessary, for the following purposes and on the following legal bases:

• The processing is necessary to organise your participation in the STEP activities you register for (workshops, event pilots and online training), including granting your access to the Platform and providing support;
• Where you have given consent to the processing of your personal data, for example to communicate with you to keep you up-to-date on the latest developments, announcements, and other information about our services, events, and initiatives (including briefings, newsletters, and other information);

The processing is necessary for the pursuit of our legitimate interests:

• To carry out surveys (e.g. on the effectiveness of online communication services);
• To perform analytics on the use of the Platform and of STEP activities;
• To analyze and improve our services and communications and to monitor compliance with our policies and standards;
• To ensure our network and information security and prevent or detect security threats, frauds or other criminal or malicious activities;
• For insurance purposes;
• To exercise or defend our legal rights or to comply with court orders.

Who else may have access to your personal data?

In certain circumstances, we may share your personal data with third parties. We will only do this if we are legally permitted to do so.

When you provide us with personal data, we assume that, unless you request otherwise in writing, we may disclose it when we believe it is reasonably necessary for the performance of our duties (as set out in this Privacy Policy) or when required by applicable law.

International transfers of Information

When we transfer your personal data to foreign countries, we protect it in accordance with this Privacy Policy.

In any case, VO GROUP will not transfer your data outside the European Economic Area ("EEA") without your consent.

Security of your personal data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We put in place strict confidentiality agreements (including data protection obligations) with our third-party service providers.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your rights

You have various rights with respect to our use of your personal data:

• Access: The right of access gives you the right to obtain a copy of your personal data.
• Rectification: You have the right to have inaccurate personal data rectified and to have incomplete personal data completed. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or has changed, so that we can keep your personal data up-to-date. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
• Erasure: You have the right to have your personal data erased. This right is not absolute and only applies in certain circumstances (for example if your personal data is no longer necessary for the purposes for which it was collected, or when your personal data have been unlawfully processed).
• Restriction: You have the right to restrict the processing of your personal data in certain circumstances. This means that you can limit the way that we use your personal data where you have a particular reason for wanting the restriction. This may be because you have issues with the content of the information we hold or how we have processed your data.
• Portability: This right allows you to request the communication of your personal data in a structured, commonly used and machine-readable format. It also offers you the possibility to transfer this data to another controller. This right to portability only applies if the legal basis for processing your personal data is consent or for the purposes of a contract, and where we carry out the processing by automated means (excluding, for example, paper documents).
• Objecting: You have the absolute right to object to the processing of your personal data if it is for direct marketing purposes. In other specific circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data.
• Complaints: We are committed to working with you to obtain a fair resolution of any complaint or concerns about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint with a supervisory authority, in the Member State of your habitual residence, of your place of work or of an alleged infringement of the data protection laws (for Belgium see www.dataprotectionauthority.be and for other countries click here). You also have the right to seek a remedy through the courts.

You may, at any time, exercise any of the above rights, by contacting us using the contact details provided below. If we have doubt about your identity, we may request you to provide us with a proof of your identity, i.e. a copy of your ID card, or passport, or any other valid identifying document.

Withdrawal of consent

When personal data is processed on the basis of your consent, you may withdraw consent at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.

In the event that you no longer want to receive any marketing communications from us, please use the unsubscribe option (which is in all of our marketing emails to you), or contact us using the contact details provided below. Withdrawal of consent to receive marketing communications will not affect the processing of personal data for the organisation of your participation in STEP activities.

How long do we keep your personal data?

We limit the retention of your personal data to the period necessary to fulfil the purposes for which it was collected, including to meet legal and accounting requirements and, where applicable, to defend our interests in legal proceedings, until such proceedings have been concluded.

At the end of the applicable retention period, we will destroy your personal data, securely and in accordance with applicable laws and regulations.

Cookies

To learn more about our use of cookies or similar technology please check our cookies policy here.

Changes to our Privacy Policy

We reserve the right to update and change this Privacy Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.

This Privacy Policy was last updated in October 2026. Please check back regularly to keep informed of updates to this Privacy Policy.

Contact Details

Please direct any questions, comments, or requests regarding our Privacy Policy to our Privacy Team: