Updated April 6, 2021

  1. Parties and Purpose

Sleyah (hereinafter “Sleyah” or the “Data Controller“)
Email : [email protected]

Sleyah establishes this Privacy Policy, the purpose of which is to transparently inform Users of the website hosted at the following address: https://sleyah.com, (hereinafter the “Site“), of the how personal data is collected and processed by Sleyah.

The term “User” refers to any user, either any natural or legal person, of legal age according to the laws in force in his country, who visits or interacts in any way with the Site.

As such, Sleyah determines all the technical, legal and organizational means and purposes of processing Users’ personal data. Sleyah undertakes to this end to take all the necessary measures to guarantee the processing of personal data in accordance with the law of July 30, 2018, relating to the protection of natural persons with regard to the processing of personal data (hereafter: after, “the Law“) and the European Regulation of 26 April 2016 on the protection of data of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “Regulation“).

Sleyah is free to choose any natural or legal person who processes the personal data of users at its request and on its behalf (hereinafter the “Subcontractor“). If necessary, Sleyah undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organizational security measures for the processing of personal data, with regard to the Law and the Regulations.

  1. Processing of personal data

L’utilisation du Site par les Utilisateurs pourra entraîner la communication de données personnelles. Le traitement de ces données par Sleyah, en sa qualité de Responsable du traitement, ou par les prestataires agissant au nom et pour le compte de Sleyah, sera conforme à la Loi et au Règlement.

Use of the Site by Users may result in the communication of personal data. The processing of this data by Sleyah, in its capacity as Data Controller, or by service providers acting in the name and on behalf of Sleyah, will comply with the Law and the Regulations.

Personal data will be processed by Sleyah, in accordance with the purposes listed below, via:

  • the use of cookies;
  • the newsletter subscription form;
  • making contact via the contact form;
  • creating an account;
  • the use of chat;
  • the automated procedure when purchasing content;
  • the manual procedure when purchasing content
  1. Purpose of processing personal data

The purposes of the processing of personal data are communicated to the User and are as follows:

  1. ensure the performance of the services offered and agreed on the Site;
    2. monitor the performance of the services offered;
    3. carry out marketing and promotional information activities after prior consent of the User and until the revocation of this consent, for example the sending of promotions on the products and services of the Data Controller;
    4. respond to User inquiries;
    5. produce statistics in order to improve the Website, the services offered and the internal organization of operation;
    6. improve the quality of the Site and the products and/or services offered by Controller;
    7. allow better identification of the User’s centers of interest.
  2. Personal data likely to be processed

The User agrees, when visiting and using the Site, that Sleyah collects and processes, according to the methods and principles described in this Privacy Policy, the following personal data:

  1. The information of Users that they provide for contractual purposes and to enable the proper performance of reciprocal obligations, namely the surname, first name, address, IBAN number and bank details,…; and more generally, any information voluntarily given by the User;
    2. Information of Users by filling in forms or contacting by telephone, e-mail address or other means, for example the name, address, e-mail address and telephone number of Users.
    3. With respect to each user’s visit to the Site, the information automatically collected are:
    a. IP address, browser type and model, time zone, operating system;
    b. all the information concerning the pages that the User has consulted on the Site, in particular the URL, the browsing time, etc.
  2. Consent

By accessing the Site and using it, the User declares to have read and given his free, specific, informed and unambiguous agreement to the processing of personal data concerning him. This agreement covers the content of this Privacy Policy.

Consent is given by the User continuing to visit the Site. This consent is an essential condition to carry out certain operations on the Site or to allow the User to enter into a contractual relationship with Sleyah. Any contract between Sleyah and a User relating to the services and goods offered on the Site is subject to the User’s acceptance of the Privacy Policy.

The User consents to the Data Controller processing and collecting, in accordance with the methods and principles included in this Privacy Policy, his personal data that he communicates on the Site or on the occasion of the services offered by Sleyah , for the purposes indicated above.

The User has the right to withdraw his consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on the consent previously given.

  1. Duration of retention of Users’ personal data

The Data Controller retains personal data only for the time reasonably necessary to enable the fulfillment of the purposes for which they are processed.

This duration is, in all cases, equal to a maximum of 1 year.

  1. Data recipients and disclosure to third parties

Personal data may be transmitted to Sleyah employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees, and who collaborate with Sleyah in the context of the marketing of products or the provision of services. They act under the direct authority of Sleyah, and are notably responsible for collecting, processing or sub-contracting this data.

In all cases, the recipients of the data and those to whom this data has been disclosed respect the content of this Privacy Policy. Sleyah ensures that they will process this data only for the intended purposes, in a discreet and secure manner.

In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed beforehand so that he can express his consent to the use of this personal data.

  1. User Rights

At any time, the User may exercise their rights by sending a message by e-mail to the following address: [email protected]

  1. Permission to access

Sleyah guarantees the User’s right of access to their personal data. The User has the right to obtain access to said personal data as well as the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients who are established in third countries or international organisations;
  • where possible, the envisaged retention period of the personal data or, where this is not possible, the criteria used to determine this period

The Data Controller may require the payment of reasonable fees based on administrative costs for any additional copies requested by the User.

When the User submits this request electronically (via the e-mail address for example), the information is provided in a commonly used electronic form, unless the User requests otherwise. .

The copy of his data will be communicated to the User no later than one month after receipt of the request.

  1. Right of rectification

Sleyah guarantees the right of rectification and erasure of personal data to the user.

Incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User first carries out the necessary modifications himself from his user/other account, except if these cannot be carried out independently, in which case the request can be made to Sleyah.

The Data Controller notifies each recipient to whom the personal data has been communicated of any rectification of the personal data, unless such communication proves impossible or requires disproportionate effort. The data controller provides the data subject with information on these recipients if the data subject so requests.

  1. Right to erasure

The User has the right to obtain the erasure of his personal data as soon as possible.

When the Data Controller has made the personal data public and it is required to erase them under the previous paragraph, the Data Controller, taking into account the available technologies and the costs of implementation, takes reasonable measures , including of a technical nature, to inform other controllers who process this personal data that the data subject has requested the erasure by these controllers of any link to this personal data, or of any copy or reproduction thereof.

The two preceding paragraphs do not apply insofar as this processing is necessary:

  • the exercise of the right to freedom of expression and information;
  • to comply with a legal obligation which requires the processing provided for by Union law or by the law of the Member State to which the controller is subject, or to perform a task in the public interest or falling within the exercise of the official authority vested in the controller;
  • the establishment, exercise or defense of legal claims.

The Data Controller notifies each recipient to whom the personal data has been communicated of any erasure of personal data or any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate effort. The data controller provides the data subject with information on these recipients if the data subject so requests.

  1. Right to restriction of processing

The User has the right to obtain the limitation of the processing of his personal data.

The Data Controller notifies each recipient to whom the personal data has been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate effort. The data controller provides the data subject with information on these recipients if the data subject so requests.

  1. Right to data portability

Users have the right to receive personal data relating to them from Sleyah in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another controller without Sleyah obstructing it in the cases provided for by the Regulations.

When the User exercises his right to the portability of data pursuant to the previous paragraph, he has the right to obtain that the personal data be transmitted directly from one controller to another, when this is technically possible.

The exercise of the right of data portability is without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller.

The right to data portability does not affect the rights and freedoms of third parties.

  1. Right to object and automated individual decision-making

The User has the right at any time to object to the processing of his personal data due to his particular situation, including the automation of data carried out by Sleyah. Sleyah will no longer process personal data, unless there are compelling legitimate grounds for the processing which override the interests and rights and freedoms of the User, or for the establishment, exercise or defense legal rights.

When personal data is processed for prospecting purposes, the User has the right to object at any time to the processing of personal data concerning him for such prospecting purposes, including profiling to the extent where it is related to such prospecting.

When the data subject objects to the processing for prospecting purposes, the personal data will no longer be processed for these purposes.

  1. Right of complaint

The User has the right to lodge a complaint concerning the processing of his personal data by Sleyah with the Data Protection Authority, competent for Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.

A complaint can be lodged at the following addresses:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone. + 32 2 274 48 00
Fax. + 32 2 274 48 35
Email: [email protected]

The User may also lodge a complaint with the court of first instance of his domicile.

  1. Cookies

The Site uses cookies to distinguish Users of the Site. This makes it possible to provide Users with a better browsing experience and an improvement of the Site and its content. The purposes and methods of cookies are contained in this article.

  1. General principles

A “Cookie” is a file placed temporarily or permanently on the User’s hard drive during consultation of the Website, with a view to subsequent connection. Thanks to cookies, the server recognizes the User’s computer.

Cookies may also be set by third parties with whom Sleyah works.

Some of the cookies used by Sleyah are necessary for the proper functioning of the Site, others improve the User’s experience.

The User can personalize or deactivate cookies by configuring his browser.

By using the Website, the User expressly agrees to the management of cookies as described in this article.

  1. Type of cookies and purposes pursued

Different types of cookies are used by Sleyah on the Site:

  • Technical cookies: they are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the navigation of the User;
  • Statistical and audience measurement cookies: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period. Since they also indicate browsing behavior, they are an effective way to improve the User’s browsing, by displaying proposals and offers likely to interest him. They also allow Sleyah to identify possible bugs on the Website and to correct them.
  • Functional cookies: these cookies facilitate the use of the Website by remembering certain choices entered (for example, the user name or the language);
  1. Cookie retention period

Cookies are kept for the time necessary to fulfill the intended purpose. The cookies that may be stored on the User’s hard drive and their retention period are as follows:

  • “age_gate” : 1 year;
    Verifies the age of the user
  • “seopress_user_consent_accept” : 1 year;
    Used for the acceptance of the pop-in associated with cookies when a user browses the site for the first time
  • “wordpress_logged_in” : 2 weeks;
    Indicates that the user is logged in to WordPress
  • “wp_woocommerce_session” : 3 days;
    Contains a unique code for each customer so they know where to find cart data. No personal information is stored in this cookie.
  • “_GPSLSC” : 1 year;
    Stores data locally to know what items exist in the local cache. This avoids double loading of elements on a web page and improves overall performance
  • “gadwp_wg_default_dimension” : 1 year;
    Enables Google Analytics to provide site usage data
  • “gadwp_wg_default_metric” : 1 year;
    Enables Google Analytics to provide site usage data
  • “gadwp_wg_default_swmetric” : 1 year;
    Enables Google Analytics to provide site usage data
  • “wfwaf-authcookie” : 1 day;
    Used by the Wordfence firewall to perform a capability check of the current user before loading WordPress.
  • “wordpress_test_cookie” : session time;
    Checks whether your browser accepts or rejects cookies
  • “wp-settings-1” : 1 year;
    Customization of the main interface of the site.
  • “wp-settings-time-1” : 1 year;
    Customization of the main interface of the site.
  1. Cookie management

If the User does not want the Website to place cookies on his hard drive, he can easily manage or delete them by modifying the parameters of his browser. The programming of the browser also allows the User to receive a notice or notification as soon as a Website uses cookies and thus decide to accept this, or to refuse it.

If the User deactivates certain cookies, he accepts that the Website may not function optimally. Certain parts of the Website may therefore not be usable, or may be partially so.

If the User thus wishes to manage and/or delete certain cookies, he can do so by using the following link(s):

For Users with browser:

  • Internet Explorer : http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
  • Microsoft Edge : http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
  • Chrome : https://support.google.com/accounts/answer/61416?hl=fr
  • Firefox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
  • Safari : https://support.apple.com/kb/ph21411?locale=fr_CA
  1. Limitation of liability of the Data Controller

The Website may contain links to other websites owned by third parties unrelated to Sleyah. The content of these sites and their compliance with the Law and Regulations are not the responsibility of Sleyah.

All content available on https://sleyah.com is strictly reserved for an adult public (according to the laws in force in the User’s country) and warned, it must be consulted only in a private setting in front of adults ( according to the laws in force in the country of these) and consenting. The content offered here remains within the framework of fantasy and can in no way be judged as incitement to hatred, violence, discrimination or to commit criminal acts. Sleyah cannot be held liable if, despite the precautions taken by the Site, minors access (for example, and without this being exhaustive, by entering incorrect data – in particular concerning age) the content of the Site.

Sleyah is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or following computer attacks.

  1. Applicable law and competent jurisdiction

This Privacy Policy is exclusively governed by Belgian law. Any dispute will be brought before the courts of the judicial district of the registered office of Sleyah.

  1. Contact

For any question or complaint relating to this Privacy Policy, the User may contact the Data Controller via the following address: [email protected]