Privacy Policy

1. Introduction

ECICEL respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our applications, websites (regardless of where you visit from). This Policy will also tell you about your privacy rights and how the law protects you

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

2. Important information and who we are

ECICEL commitment to you

We are committed to protecting your personal information in accordance with the European Union’s General Data Protection Regulation (GDPR) and best practices. This Privacy Policy outlines how we manage and use your data. By using our website, you consent to this policy.

3. What this Policy is about

This privacy policy aims to give you information on how ECICEL collects and processes your personal data through your use of our websites (including this www.ecicel.org).

This Policy also explains how and when information may be shared with our Affiliates and Partners if you want to engage with them directly and purchase their products or services.

This Policy also covers our use of your data if you work for one of our Affiliates, Partners or suppliers. This policy also sets out when we may communicate with you in relation to our services and business.

Not intended for children: The ECICEL are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy information or notices we provide, so that you may understand how we use and keep your data secure.

We take every reasonable step to keep your data secure. Our website is protected by Cloudflare and SSL to ensure the privacy and security of your data. All online forms accessed directly from our website use a 128-bit Secure Socket Layer.

Please contact us at office[at]ecicel.org if you have any questions or would like further information.

4. Controller

ECICEL is the Data Controller under data protection law, and this means we are responsible for determining how and why personal information provided to us is processed, as well as keeping it secure.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO on office[at]ecicel.org

5. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Privacy Manager/DPO in the following ways:

Email address: office[at]ecicel.org

You have the right to make a complaint at any time to the Data Protection Inspectorate, the Estonia supervisory authority for data protection issues (https://www.aki.ee/).

6. Changes to the privacy policy and your duty to inform us of changes

We may update this privacy policy from time to time to reflect changes in the law, our website’s functionality, or our data management practices. We encourage you to periodically review this policy to stay informed about how we manage and use your data.

7. The information we collect about you

Personal data, or personal information, means any information about you from which you can be identified.

We may collect, use, store and transfer different kinds of personal data about you, depending on why you are engaging with us:

If you are a ECICEL User / Subscriber, we may process the following personal information about you:

• Identity Data includes first name, maiden name, last name.
• Contact Data includes address, email address and telephone numbers.
  
• Marketing and Communications Data includes your preferences in receiving marketing from us, any third parties and your communication preferences, including registering for our newsletter.

8. How is your personal data collected?

We use different methods to collect data from and about you including through:

• application form 
• subscribe to our newsletter or mailing list;
• request marketing to be sent to you;
• respond to a survey or provide feedback.

9. How we use your personal data

On what basis will we process your information? 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 you- for example when you open a ECICEL Service;
• Where it is necessary for our legitimate interests;
• Where we have your consent- for example confirm you want to hear about relevant activities and services.
• Where we need to comply with a legal obligation.

• Purposes for which we will use your personal data
  

10. Purpose/Activity Type of data

Lawful basis

Application form ECICEL

About whom you are and how to contact you.

To perform a contract with you (i.e. access our service. Necessary for our legitimate interest.

To manage our relationship with ECICEL Users which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to provide feedback or take a survey	Information about who you are and how to contact you. Information relating to your Account profile and preferences/settings on marketing and communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (c) consent in some instances for marketing
To administer and protect our business and ECICEL Platforms	Information on who you are, how you use or ECICEL Platforms, what devices you use. Information on how you use our services.	(a) Necessary for our legitimate interests (for running our business, improving our services, providing relevant information on activities and services, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

To use data analytics to improve Information about how Necessary for our legitimate interests  

ECICEL Memberships

you use our ECICEL Platforms

If you apply for ECICEL membership, we will require you to complete a secure online form. You will need to provide information about your institution or organization, including contact and ownership information, and details of your operations management and policies.

11. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the Cookies Policy.

12. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal third parties such as our employees or officers and legal entities within the ECICEL group of companies.
  
• With Affiliates and Partners.
  
• With research and trial partners, being commercial research, academic organisations.
  
• External third parties including clients, payment providers, specialist IT support, cloud hosting providers, communications partners and sub-contractors.
  
• Professional advisers including lawyers, bankers, marketing agencies, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  
• Credit reference agencies, law enforcement and fraud prevention agencies.
  

13. International transfers

We do not usually or regularly transfer data outside of the EU in the course of our business. In the event we transfer your personal data out of the EU, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Data security

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the EU Government (including the EEA as at the date of this version of the Policy).
  
• Where we use certain service providers, we may use specific contracts approved for use in the EU which give personal data the same protection it has in the EU, as well as conducting an appropriate risk assessment.

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 take every reasonable step to keep your data secure. Our website is protected by Cloudflare and SSL to ensure the privacy and security of your data.

14. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

For ECICEL Users we usually retain some of your personal data, which may include Sensitive Data, for a period of 6 years after you have finished using our services. This is the minimum information required to ensure we can provide relevant information to you and respond to any queries, complaints or claims.

If you are an Affiliate, Partner or other supplier, we usually keep information for 6 years after the last purchase or invoice, however, though this is usually organisational information and any personal data is just retained on an ancillary basis (e.g. your name is on an invoice)

15. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

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 objected 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 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:

• If you want us to establish the data’s accuracy.
  
• Where our use of the data is unlawful, but you do not want us to erase it.
  
• 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.
• 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. ECICEL Users can manage some consents given through the ECICEL Account settings. 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.

If you wish to exercise any of the rights set out above, please contact us and/or check you ECICEL Account settings.

16. No fee is 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 could refuse to comply with your request in these circumstances.

17. 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). We may also contact you to ask you for further information in relation to your request to speed up our response.

18. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.