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    INSOL Europe Privacy Policy


    1. Who We Are
    INSOL Europe collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including the United Kingdom) and we are responsible as the ‘controller’ of that personal information for the purposes of those laws.
     
    This notice provides you with information about your rights and obligations, and explains how, why and when we collect and process your personal data.
     
    We are an unincorporated association registered in France under reference number 64977 and have our registered office at 106 rue La Boétie, 75008 Paris. Our main trading address is PO Box 7149, Clifton, Nottingham NG11 6WD. We are a French non-profit making organisation.
     
    We are registered on the Information Commissioner’s Office Register of controllers under registration number Z8067110 and act as the controller and our contact details are: Caroline Taylor, Email: carolinetaylor@insol-europe.org
     
    We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

    2. What is Personal Data?
    Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

    In simpler terms personal data is any information about you which enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
     
    3. The Personal Data We Collect and Use
    In the course of our activities with you, we will collect the following personal data from you:
    • Your forename and surname
    • Your date of birth
    • Your professional association details
    • Your email
    • Your mobile or landline numbers
    • Your address
    • Your individual/company website details
    • Personal data relating to your profession
    • Personal data relating to any membership to any professional body
    • Personal data relating to any membership renewals
    • Personal data you provide to us on a voluntary basis by using our website, our products or services,
    • Personal data you provide to us when you interact with us online, or by phone, email or otherwise.
    We do not collect special categories of data.


    4. How we Collect your Personal Data
    We may collect this information directly from you. Your personal data may be obtained from third party companies as long as they meet the GDPR requirements. In such a case you will receive a privacy notice and be notified on the categories of data we have obtained and sources we have obtained your data from within one month from collection and in any case at the moment of our first communication with you.


    5. Why we collect the information and how we use it?
    We will typically collect and use this information for the following purposes:

    • In order to provide and manage your membership.
    • To supply our products and services to you.
    • In order for us to enter into a contract with you.
    • In order to communicate with you. This may include responding to emails or calls from you.
    • In order to supply you with information by email and/or by post that you have requested.  You may un-subscribe or opt-out at any time by emailing us at carolinetaylor@insol-europe.org or writing to us at our trading address.
    With your permission, and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to protect your rights fully and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

    6. Reasons we can collect and use your Personal Data
    INSOL Europe processes your personal data for the following reasons:
    1. The processing is necessary for our legal, statutory obligations; and
    2. The processing is necessary for the performance of a contract with you and to provide you with our products and services.
    We will never collect any unnecessary personal data from you and do not process your personal data in any way, other than as specified in this notice.
     
    7. How We Use Your Personal Data
    INSOL Europe takes your privacy very seriously and will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time.  
     
    The purposes and reasons for processing your personal data are detailed below:
    • Sending you information about our services
    • Sending you information about conferences and events that you have registered for, or may be interested in attending
    • Sending you information about other products, e.g. newsletters, that we produce from time to time
    • Internal record keeping
    8. INSOL Europe will comply with the GDPR data processing principles
    We will comply with the data protection principles when gathering and using personal information, namely that your personal data will be:
    1. processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
    2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’);
    3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
    4. accurate and kept up to date (‘accuracy’);
    5. not kept longer than necessary (‘storage limitation’);
    6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

    9. Who we share your Personal data with
    INSOL Europe may disclose your personal data:
    • to third-party organisations (including online organisations) as part of meeting our contractual obligations with you;
    • to professional accountants and/or tax bodies for legal compliance reasons;
    • where required by law, or in connection with legal proceedings, or for the prevention/detection of crime, or for the collection of tax;
    • to law enforcement or other authorities if required by applicable law;
    • to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf.
    If any personal data is transferred outside the EEA, this will be within our group and we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.

    10. Where we Hold and Transfer your Personal Data?
    We store your data locally in our offices and digitally at the following locations:
    PO Box 7149, Clifton, Nottingham NG11 6WD, UK
    U-Store, New Basford, Nottingham NG7  7EA, UK
     
    We also store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

    We would only share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage.
    The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including: transferring it using SSL and storing it in encrypted form.

    If you would like further information please contact Caroline Taylor, Email: carolinetaylor@insol-europe.org. We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

    11. Your Rights
    Under the GDPR you have a number of important rights free of charge. In summary, those rights include the following:
    1. Right of access to your personal data – you have the right to request a copy of the information that we hold about you. Please refer to clause 9 regarding Subject Access Request (SAR) below
    2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
    3. Right to Erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records.
    4. Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
    5. Right to object – you have the right to object to certain types of processing such as direct marketing.
    6. Right to be informed you have the right to be informed regarding how your personal data is being processed (including the right to be notified by us of any erasure, rectification or restriction of processing of your personal data).
    7. Right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause below ‘complaints’. 
    For further data on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Data Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

    If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information (refer to clause 11.2) and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

    You also have the right to request erasure (refer to clause 11.3) of your personal data or to restrict processing, (refer to clause 11.4)  in accordance with data protection laws, as well as to object to any direct marketing from us (refer to clause 11.6) and to be informed about any automated decision-making that we use (refer to clause 11.7). 

    If we receive a request from you to exercise any of the above rights, we will ask you to follow the instructions below:
    • email Caroline Taylor: carolinetaylor@insol-europe.org
    • let us have enough data to identify you (e.g. name, membership number),
    • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
    • let us know the data to which your request relates including any account or reference numbers, if you have them.
    If you would like to unsubscribe from any newsletter you can also click on the ‘unsubscribe’ button at the bottom of the relevant newsletter.

    12. Subject Access Request (SAR)
    You have the right to access any personal data that we process about you and to request information about:
    ·       What personal data we hold about you
    ·       The purposes of the processing
    ·       The categories of personal data concerned
    ·       The recipients to whom the personal data has/will be disclosed
    ·       How long we intend to store your personal data for
    ·       If we did not collect the data directly from you, data about the source
     
    If you want to know what personal data we have about you, you can ask us, free of charge, using what is called a “subject access request” for details of that personal data and, if we do hold such personal data, for a copy of it.

    If your request is ‘manifestly unfounded or excessive’ (for example if you repeatedly ask for the same information) then we may charge you to cover our administrative costs in responding.

    We will do our best to respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.

    Please contact Caroline Taylor, Email: carolinetaylor@insol-europe.org if (in accordance with applicable law) you would like to exercise the above stated rights or if you have any questions about this notice.   

    13. Safeguarding Measures
    INSOL Europe takes every reasonable measure and precaution to protect and secure your personal data from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including SSL and other industry standard encryption.
    Those processing your data will do so only in an authorised manner and are subject to a duty of confidentiality.
     
    We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

    14. Consequences of Not Providing Your Data (if applicable, see Article 13(2)e)
    Members are required to provide us with personal data. If you do not do so we may not be able to fulfil our commitments to you.

    15. How Long We Keep Your Personal Data
    INSOL Europe only ever retains personal data for as long as is necessary and we have strict review and retention policies in place to meet these obligations. 
    Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

    16. Lodging A Complaint
    We hope that we can resolve any query or concern you raise about our use of your information.
     
    In the event that you wish to lodge a complaint about the processing of your personal data or you are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority and Caroline Taylor, Email: carolinetaylor@insol-europe.org
     
      Information Commissioner’s Office INSOL Europe
    Contact Name:   Caroline Taylor
    Website: https://ico.org.uk www.insol-europe.org
    Email: casework@ico.org.uk carolinetaylor@insol-europe.org
    Telephone: 0303 123 1113 +44 (0) 115 8780584








    17. Changes to this privacy notice
    This privacy notice was published on 1 May 2018 and last updated 20 August 2018.
    We may change this privacy notice from time to time, and updates will be published on the website.