Privacy policy

Privacy Policy

Last Updated: June 20, 2025

1. Introduction and Data Controller

This Privacy Policy explains how Juliard.Club ("we," "us," or the "Data Controller") collects, processes, and protects personal data on our website, www.juliard.club (the "Site"), including through our AI-powered chatbot. We comply with the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data and Regulation (EU) 2016/679 (GDPR).

Data Controller:

We determine the purposes and means of data processing and ensure our processors comply with GDPR.

2. Processing of Personal Data

We collect and process personal data when you use our Site or interact with our chatbot, including data provided via forms, cookies, newsletter subscriptions, or automated processes. Processing is conducted lawfully under GDPR and Belgian law for the purposes below.

3. Purpose of Data Processing

We process personal data to:

  • Provide and manage Site services, including customer support via our chatbot.
  • Process orders and fulfill contracts.
  • Send newsletters (if subscribed).
  • Improve Site and chatbot functionality using cookies and analytics.
  • Respond to inquiries and provide support.

4. Types of Personal Data

We collect and process:

  • Contractual data (e.g., name, address, payment details).
  • Cookie data (e.g., browsing behavior, preferences).
  • Contact data for newsletters or inquiries (e.g., email).
  • Chatbot data (e.g., name, email, conversation history for support).

5. Consent

By using our Site, selecting preferences in our cookie banner, interacting with our AI chatbot (via Smartsupp), or checking the Privacy Policy consent box, you provide free, specific, informed, and unambiguous consent to process your personal data. The chatbot requires consent to collect data (e.g., name, email, conversation history) for support. You may opt out of non-essential processing (e.g., analytics, AI training) via the chatbot or cookie banner. Consent can be withdrawn anytime by contacting us or using the consent tools, without affecting prior lawful processing. Service access is not conditioned on non-essential data processing.

6. Data Retention Period

We retain personal data, including chatbot data, only as necessary for the purposes outlined (e.g., support, analytics) and no longer than one year unless required by law. Data used for AI training, if consented to, is anonymized and retained per Smartsupp’s policies.

7. Data Recipients and Third Parties

Personal data, including chatbot data, may be shared with employees, subcontractors, or third-party providers like Smartsupp (EU-based), who process data under our instructions and a GDPR-compliant Data Processing Agreement (DPA). Smartsupp provides our AI chatbot for support and may use data for analytics or, with consent, AI improvement. We obtain prior consent for marketing or AI training. Data transfers outside the EU/EEA use safeguards such as Standard Contractual Clauses (SCCs) or the EU-U.S. Data Privacy Framework (DPF).

8. User Rights

You can exercise GDPR rights for data collected via the Site or chatbot by contacting us at juliard.club@gmail.com or Akkerstraat 11, 8020 Waardamme, Belgium (include a copy of your ID):

  • Access: Request a copy of your data, including chatbot history.
  • Rectification: Correct inaccurate data, including chatbot records.
  • Erasure: Request deletion per GDPR Article 17.
  • Restriction: Limit processing per GDPR Article 18.
  • Portability: Receive data in a machine-readable format (e.g., JSON, CSV).
  • Objection: Object to marketing or analytics processing.
  • Automated Decision-Making: Our chatbot does not make significant automated decisions. If this changes, we ensure human oversight and contestation rights.

Requests are processed within one month. Additional copies may incur a fee. In case of a data breach, we notify the Belgian Data Protection Authority within 72 hours and users if high risk. Lodge complaints at:

9. Cookies

We use cookies, including Smartsupp’s for chatbot functionality, to enhance your experience. A cookie banner lets you choose non-essential cookies. Cookies include:

  • Technical Cookies: Essential for Site and chatbot (no consent required).
  • Statistical Cookies: Track behavior for analytics (requires consent).
  • Functional Cookies: Save preferences (requires consent).
  • Tracking Cookies: Measure interactions (requires consent).

Cookies are stored up to one year or session duration. Manage consent via the cookie banner or browser:

Opt out of Google Analytics: Google Analytics Opt-Out. Disabling cookies may affect chatbot functionality.

10. Data Protection Impact Assessments

Our Smartsupp AI chatbot does not engage in high-risk processing. If future features involve systematic monitoring or sensitive data, we will conduct Data Protection Impact Assessments (DPIAs) per GDPR Article 35.

11. International Data Transfers

Chatbot data is hosted in the EU by Smartsupp. If sub-processors transfer data outside the EU/EEA, we use SCCs or the EU-U.S. DPF to comply with GDPR Chapter V.

12. Data Security and Breach Notification

We use encryption and access controls for Site and chatbot data. In case of a breach, we notify the Belgian Data Protection Authority within 72 hours and users if high risk, per GDPR Articles 33–34.

13. Changes to Privacy Policy

We may update this policy to comply with legal requirements. Changes will be posted on the Site or emailed. Review it regularly.

14. Applicable Law and Jurisdiction

This policy is governed by Belgian law. Disputes are resolved in the courts of Juliard.Club’s judicial district.

15. Contact Information

For questions or complaints: