EEMA PRIVACY NOTICE
27th July 2018
EEMA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we use and look after your personal data when you visit our website and when we provide our services to you regardless of where you visit from and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1, Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how EEMA collects and processes your personal data through all your engagements with us, when using our products and services and use of our websites, including any data you may provide when you sign up to our services, our newsletters or request information about other services from EEMA.
These websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
EEMA is the controller and responsible for your personal data (collectively referred to as " EEMA ", "we", "us" or "our" in this privacy notice).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (including an opt-out mentioned in this privacy notice), please contact the DPO using the details set out below.
Data Protection Officer
Email: dpo@ EEMA.org
Address: EEMA, Rue Washington 40, Brussels 1040, Belgium
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 27th July 2018
The data protection law in the UK changed on 25 May 2018. The applicable law is defined under the heading “Law” in the glossary. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests immediately as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. All Personal data we hold about you is in our CRM system and your access to it is described below.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Although we security vet all the links we put on our site we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed..
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes - first name, last name, username or similar identifier, title.
- Contact Data includes - billing address, delivery address, email address and telephone numbers.
- Financial Data includes - bank account and payment card details.
- Transaction Data includes - details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes - internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website [and our services.
- Profile Data includes - your username and password, services purchased by you, preferences, feedback.
- Usage Data includes - information about how you use our website, services.
- Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data)
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, entering into agreements or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
- Apply for our products and services,
- Enter into an agreement with us;
- Subscribe to our service or publications;
- Attend one of our events
- Give us some feedback.
If you respond to information about EEMA you have seen elsewhere (e.g.Twitter, LinkedIn etc.) by requesting information you will be asked to enter your personal details and preferences on our site. The link to do this is currently https://eema.wildapricot.org/
Log in – if you have never done so you will need to request a password (it comes through automatically and is not stored on the system)
Once logged in you have full transparency and control of the personal data we hold about you including your preferences.
We currently group the personal data we hold into 3 Categories
Members – Fully paid up Members of the Association
Associates – Individuals with whom we have a legitimate business relationship e.g. Previous speakers, Industry experts etc.
Prospects – everybody else e.g those who has previously shown interest in EEMA , attended or enquired about events etc.
Everybody on our records falls into one of these categories and our indications from email testing show a better than 99% delivery rate.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your ,browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers such as Google based outside the EU;
- Credit and reference checking agencies
- Partner networks
- Identity and Contact Data from publicly availably sources such as Companies House based inside the EU
5, How we use your personal data
You have full visibility of and access to the personal data we hold about you through the link we provide in our mail contacts with you. You have full visibility, edit and delete rights to these data and you can delete your account if you wish. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with our clients, partners and distributors.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- To inform you of relevant products, activities and services from EEMA and our key partners
Generally since by being on our records you have previously shown interest as above we do not rely on consent as a legal basis for processing your personal data. In relation to sending third party direct marketing communications to you via email or text message we shall do this. (As you have the ability to notify us of your specific interests directly on your record). You have the right to withdraw consent to marketing at any time by contacting us or amending/deleting your record.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new member or interested party||(a) Identity
|Legitimate Interest – providing a service to both members and the wider relevant EEMA community|
|To process your agreement including:
(a) Manage membership, attendance at events, payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you - member and event attendee
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Sending ours and our partners newsletters, informing you of relevant conferences and events or take a survey
(d) Marketing and Communications
|(a) Necessary for our legitimate interests – providing a service
(b) Necessary for our legitimate interests to keep our records updated as to areas of interest and to study how interested parties use our services
|To deliver relevant website content and potential available services to you and measure or understand the effectiveness of the content we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests to study how visitors to our website use our services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, services, marketing, relationships and experiences||(a) Technical
|Necessary for our legitimate interests to define types of interested parties for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
|To make suggestions and recommendations to you about products or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests to develop our services and grow our business.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications.
You will receive marketing communications from us if you have requested information from us or entered into a contract for services from us or if you provided us with your details when you registered interest and, in each case, you have not opted out of receiving that marketing.
Third-party marketing – We do not share your details with third party partners.
You can ask us to stop sending you our partners marketing and communications emails at any time by following the opt-out links on any marketing or communication message sent to you or by contacting us at any time - EEMA: Rue Washington 40, Brussels 1040, Belgium, or email: dpo@ EEMA.org
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any contractual or legal relationship we have with you.
We employ cookie technology to help log visitors to our web site. Cookies are pieces of data that are often created when you visit a website, and which are stored in the cookie directory of your computer or mobile device. A number of cookies may be created when you visit the EEMA website. The cookies do not contain any personal information about you, and they cannot be used to identify an individual user.
When you visit this website we collect web statistics concerning your visit, which are stored in a log file. Log files allow us to record visitors’ use of the site. Log files are also used to detect potential harmful users which may be reported to the relevant authorities.
5. Disclosures of your personal data
We may have to share your personal data with relevant third parties for the operation of your contract with us, for example to enable us to take payment for subscriptions.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions
6, International transfers
We use Internationally hosted companies for the provision of some services e.g. email and content management. These are covered by international agreements with the EU for the transfer and Protection of personal data. e.g. Privacy Shield. We have signed Data Processing Agreements with all such service providers to ensure they comply with UK law in respect of processing and securing your data.
Our Website is hosted in UK. The services we use outside the UK as above act as Data Processors on our behalf.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your personal access to your records is available all the time. Should that fail for any reason you can ask us to delete your data: see [Request erasure] below for further information.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see these within the glossary below (link)
If you wish to exercise any of the rights set out below please contact us (link) or - EEMA: Rue Washington 40, Brussels 1040, Belgium, or email: dpo@ EEMA.org
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
As of the 25th May 2018 The UK Laws defining Protection on Personal Data in UK as applicable in this instance are:-, The General Data Protection Regulations (EU) (GDPR) and the Data Protection Act 2018, Privacy and Electronic Communications Regulations (PECR).
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (link)
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Service providers [acting as processors] based within the EU who provide IT and system administration services
- Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based within the EU who provide [consultancy, banking, legal, insurance and accounting services].
- HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom [who require reporting of processing activities in certain circumstances].
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.