This translation is provided for information only. In case of discrepancy, the French version prevails.
1. Introduction
Airplan SRL (hereinafter “Airplan”) is committed to protecting your personal data and to processing it in accordance with the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679 of 27 April 2016) and with applicable Belgian legislation.
This privacy policy applies to all pages hosted on https://airplan.be and to all data processing associated with our platform. We recommend that you consult it regularly, as it may change. Any amendment will take effect on the date of publication and will never be retroactive, unless otherwise required by law.
2. Data controller
Data controller: Airplan SRL, Rue des Houblonnières 53, 4020 Liège, bonjour@airplan.be, 0460 94 98 97
3. Personal data collected
We collect the following categories of data:
- Contact details (surname, first name, e-mail address, postal address, telephone number) via the contact or sign-up forms
- Data relating to your projects and your clients’ contact details, entered on the platform in the course of providing our service
- Browsing data (pages viewed, browser configuration, domain name of the Internet service provider)
- E-mail address for subscribing to our newsletter (via Brevo)
- Answers to survey forms
We do not collect any so-called “sensitive” data within the meaning of the GDPR (health, political opinions, religion, etc.).
4. Legal bases for processing
In accordance with Article 6 of the GDPR, each processing operation is based on a specific legal basis:
| Purpose | Legal basis | Details |
|---|---|---|
| Contact / sign-up forms | Consent (Art. 6.1.a) | The user gives express consent when submitting the form |
| Brevo newsletter | Consent (Art. 6.1.a) | Voluntary subscription, with the option to unsubscribe at any time |
| Analytics and marketing cookies | Consent (Art. 6.1.a) | Obtained via the cookie banner |
| Project and client data entered | Performance of a contract (Art. 6.1.b) | Necessary to provide the service subscribed to |
| Billing data | Legal obligation (Art. 6.1.c) | Retention required by Belgian tax and accounting legislation |
5. Data retention period
- Account and project data: kept until the project or account is deleted
- Browsing data and cookies: 13 months maximum (in line with the recommendations of the APD, the Belgian Data Protection Authority)
- Newsletter data: kept until you unsubscribe, then deleted within 30 days
- Billing data: 7 years (Belgian legal obligation)
Beyond these periods, your data is deleted or irreversibly anonymised.
6. Processors and data transfers outside the EU
6.1 Processors
Airplan uses the following processors, with whom data processing agreements (DPAs) have been or are to be concluded:
- Google Tag Manager and Google Analytics 4 (Google LLC): browsing statistics
- HubSpot (HubSpot Inc.): CRM and marketing
- Brevo (formerly Sendinblue): sending newsletters
- Base44 (United States): development and hosting platform for certain Airplan applications
- Amazon Web Services (AWS) (Amazon Web Services EMEA SARL, Luxembourg): hosting and cloud infrastructure
- Cloudflare (Cloudflare Inc., European branch): content delivery network (CDN) and web security
6.2 Transfers outside the European Union
Some of our processors are established in the United States. These data transfers outside the European Union are governed by the Standard Contractual Clauses (SCCs) adopted by the European Commission, in accordance with Article 46 of the GDPR.
The service providers concerned and the data transferred are as follows:
- Google LLC (Google Tag Manager, Google Analytics 4): browsing and behaviour data on the site
- HubSpot Inc.: contact data and marketing interaction data
- Base44 (United States): account, project and client data entered on the Airplan platform. Base44 acts as a processor within the meaning of Article 28 of the GDPR and processes this data solely to provide the service, on Airplan’s instructions.
Airplan does not transfer your personal data to third parties for commercial purposes without your explicit consent.
7. Use of cookies
Cookies are small files placed on your device when you visit our site. We use the following technologies:
- Google Tag Manager: centralised tag management
- Google Analytics 4: audience measurement and analysis of visitor behaviour
- HubSpot: marketing tracking and customer relationship management
These analytics and marketing cookies are only placed after you have given your consent via our cookie banner. You can change your preferences at any time by clicking the “Manage my cookies” link at the bottom of every page.
If you refuse cookies, some features of the site may be limited. You can also set your browser to block cookies or to alert you when cookies are being placed (see your browser’s Help menu).
Cookie retention periods are limited to 13 months maximum, in line with the recommendations of the Belgian Data Protection Authority (APD).
8. Web beacons
Some pages of the site and some e-mails may contain web beacons (one-pixel electronic images) used to count the number of visitors, or of subscribers who have opened an e-mail. These beacons are used for statistical purposes only and do not allow you to be personally identified.
9. Data security
Airplan implements appropriate technical and organisational measures to protect your data against loss, unauthorised access, disclosure, alteration or destruction, in accordance with Article 32 of the GDPR.
However, no transmission of data over the Internet can be 100% guaranteed. In the event of a data breach likely to result in a risk to your rights and freedoms, Airplan will notify the APD within 72 hours and will inform you if the risk is high.
10. Your rights
Under the GDPR (Articles 15 to 22), you have the following rights regarding your personal data:
- Right of access: obtain a copy of the data we hold about you
- Right to rectification: correct inaccurate or incomplete data
- Right to erasure (“right to be forgotten”): request the deletion of your data in certain cases
- Right to restriction of processing: restrict the use of your data in certain cases
- Right to data portability: receive your data in a structured, machine-readable format
- Right to object: object to processing based on legitimate interest
- Right to withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal
To exercise these rights, contact us at: bonjour@airplan.be or by post at Airplan SRL, Rue des Houblonnières 53, 4020 Liège. We will reply within a maximum of 30 days.
You also have the right to lodge a complaint with the Belgian Data Protection Authority (APD):
- Website: www.autoriteprotectiondonnees.be
- Telephone: +32 2 274 48 00
- Address: Rue de la Presse 35, 1000 Bruxelles
11. Changes to this policy
Airplan reserves the right to amend this policy. In the event of significant changes affecting your rights, we will inform you by e-mail or through a clearly visible notice on our site before the changes take effect. No change will apply retroactively.
12. Contact
- E-mail: bonjour@airplan.be
- Telephone: 0460 94 98 97
- Postal address: Airplan SRL, Rue des Houblonnières 53, 4020 Liège