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Privacy Policy 2.0

01 June 2018

We want all our members, course providers and supporters to feel confident and comfortable with how any personal information you share with us will be looked after or used. This Privacy Policy sets out how we collect, use and store your personal information (this means any information that identifies or could identify you).

This Privacy Policy may change so please remember to check back from time to time, this is version 1.0 and was last updated on the 22nd May 2018. Where we have made any changes to this Privacy Policy, we will make this clear on our website or contact you about any changes.

 

1.           Who we are

2.           How we collect information about you

3.           Information we collect and why we use it

4.           Legal basis for using your information

5.           Marketing

6.           Sharing your Information

7.           Keeping your information safe

8.           How long we hold your information for

9.           Your rights

10.         Cookies

11.         Monitoring

1.       Who we are

WICE is committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.

We are a "data controller" for the purposes of the EU General Data Protection Regulation 2016/679 ("Data Protection Law").  This means that we are responsible for, and control the processing of, your personal information.

Our Data Protection Officer is: Andrew Insley

For further information about our privacy practices, please contact our Data Protection Officer by:

  • Writing to10 rue Tiphaine, 75015 Paris, France
  • Calling us on 01 45 66 75 50
  • Emailing, dataprotection@wice-paris.org

 2.       How we collect information about you

Everything we do, we do to ensure that you can access the classes, events and other resources that WICE provide and in case we need to contact you in an emergency. We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls. We want to make sure you receive the best attention when you book an event, become a member or make a donation.

We collect information from you in the following ways:

When you interact with us directly: This could be if you become a member, register with us for a course or an event, donate to us, ask a question, apply for a volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, or get in touch through the post, or in person.

When you visit our website:

1.           Information about your computer and about your visits to and use of this website (geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. We don’t track IP addresses);

2.           Information that you provide to us when registering with our website, including your email address;

3.           Information that you provide when completing your profile on our website, including your name, address, phone number, gender and nationality;

4.           Information that you provide to us for subscribing to our email notifications and/or newsletters, including your name and email address;

5.           Information relating to any purchases you make of our services or any other transactions that you enter through our website, including your name, address, telephone number and email address;

6.           Information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts); 

7.           Information contained in or relating to any communications that you send to us or send through our website, including the communication content and metadata associated with the communication;

We use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you and our members or visitors to our website. Wherever possible we use anonymous information which does not identify individual visitors to our website.


3.   Information we collect and why we use it

Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone and mobile numbers and credit/debit card details (if you are making a purchase or donation), as well as information you provide in any communications between us.  You will have given us this information whilst donating, registering for an event or course on our website or any of the other ways to interact with us.

We may use your personal information to: 

 Administer our website and business;

1.           Enable your use of the services available on our website;

2.           Supply services purchased through our website;

3.           Send statements, invoices and payment reminders to you, and collect payments from you;

4.           Send you non-marketing commercial communications;

5.           Send you email notifications that you have specifically requested;

6.           Send you our email newsletter, if you have requested it, you can inform us at any time if you no longer require the newsletter;

7.           Send you marketing communications relating to our business which we think may be of interest to you, by email, you can inform us at any time if you no longer require marketing communications;

8.           Deal with enquiries and complaints made by or about you relating to our website;

9.           Keep our website secure and prevent fraud;

10.         Verify compliance with the terms and conditions governing the use of our website.

11.         If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

12.         All our website financial transactions are handled through our payment services provider, PayPal. You can review the provider's privacy policy at www.paypal.com/fr/webapps/mpp/ua/privacy-full We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds. We also accept credit card information by telephone or face-to-face.

13.         To contact you about our events and courses and how you can support WICE (see section 8 on 'Marketing' below for further information).

14.         To invite you to participate in surveys or research.

If you do not provide this information, we will not be able to process your donation, sign you up for an event, provide services you have requested, or effectively administer your membership, event attendance or the volunteering arrangement that you have entered into with us.


    4.       Legal basis for using your information

    Under EU data protection law, we must have a valid basis for using your personal information and we may not collect store or use information other than as described in this policy. There are four ways we may have a valid basis for using your personal information:

    1.           Contract—Most of the information we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide details when you become a member or sign up for one of our events.

    2.           Consent—When you register and open an online account with us you will be invited to give us your consent to use your personal information as described in ‘Agree to WICE’s privacy policy. By opting in you are giving us your permission to process your data using consent as our legal basis. If you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time.

    3.           Legitimate Interests—We have a legitimate interest in using your personal information. If this is our reason for using your personal information, we must make sure that our interests do not override yours and you can object to this use of your personal information.

    4.           Legal Obligation—Lastly, we have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.

    A full description of the different types of personal information we process, the purpose of the processing and the legal basis for the processing is shown below:

    Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively.To create statistical information, market research, analysis and group profiles to better manage and run our organisation.
    Our use of your data  Legal basis for processing 
    To carry out our contract with you to provide you with membership services or allow you to attend one of our events. Necessary for the performance of our contract with you or to take steps to enter into that contract.
    To notify members and event attendees of any changes to our service. Necessary for the performance of our contract with you or to take steps to enter into that contract
    To provide you with marketing information via email, post or other electronic means about goods and services we believe may be of interest to you. You have given us your consent, or we rely on legitimate interest. See section 5.
    To understand the effectiveness of the online advertising we show you and to deliver relevant advertising to you via our website. Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is relevant.
    To ensure that the content on our website is presented to you and your computer as effectively as possible. Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively.
    To create statistical information, market research, analysis and group profiles to better manage and run our organisation. Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively.
     To provide data to public authorities where legally required.  We have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.


    Our legitimate interests and your right to object

    Legitimate Interests means the interests of our organisation in conducting and managing our courses, events and other services.

    For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well.

    When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will 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).

    Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing. If you wish to do so, please let us know by contacting dataprotection@wice-paris.org. Please bear in mind that if you object, this may affect our ability to carry out the tasks for your benefit.

    Whenever we process your Personal Information under the ‘legitimate interest' lawful basis we make sure that we consider your rights and interests and will not process your personal information if we feel that there is an imbalance.

    5.       Marketing

    We will only contact you about our organisation, our aims and courses and events that we think you will be interested in. This could be by phone or email if you have agreed for us to contact you in this manner. If you have provided us with your postal address we may send you information about our work and how you can support WICE by mail unless you have told us that you would prefer not to hear from us in that way.

    You can update your choices or stop us sending you these communications at any time by updating your member profile on the website www.wice-paris.org or contacting dataprotection@wice-paris.org.

    Our marketing materials will take the following form to the following groups.

    WICE DIRECT

    This is our periodic newsletter, that will contain information on upcoming events and courses. Anyone can sign up by completing the form on the homepage. Members and those attending events can select to receive when they fill in the registration form.

    Signing up via either way is taken as consent to send you the newsletter.

    Members Messaging

    If you are a member of WICE you will receive invitations to events and other information to help you get the most out of your membership.

    You can unsubscribe from these communications by altering the options in your members page or clicking the unsubscribe page on the emails you receive.

    You have given us your consent, or we rely on legitimate interest.

    You will receive these communications up to 12 months after your membership expires
    Other Marketing 

    We may contact those who have attended courses or other events to let them know of other events that we think may interest them.

    You have given us your consent, or we rely on legitimate interest.

    You can unsubscribe from these emails in your members page or clicking on the unsubscribe in the emails you receive


    6.       Sharing your Information

    The personal information we collect about you will be used by our staff, course providers and volunteers at WICE so that they can provide the best service to our members.

    All these individuals will be required to undertake data protection training and agree to the WICE privacy guidelines so that we can ensure they understand the importance of protecting your data and have the knowledge to protect your personal data.

    We may disclose your personal information: 

    1.           To the extent that we are required to do so by law;

    2.           In connection with any ongoing or prospective legal proceedings;

    3.           To establish, exercise or defend our legal rights, including providing information to others for the purposes of fraud prevention and reducing credit risk;

    4.           To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

    5.           We do not nor will never sell or share your personal information with other organisations so that they can contact you for any marketing activities. Nor do we share any information about your web browsing activity.


    7.       Keeping your information safe

    We take looking after your information very seriously. We've implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, processing,  alteration, destruction, disclosure and loss.

    Unfortunately, the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.

    Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or Web sites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites or advertisers.

    Any debit or credit card details which we receive on our website are passed securely to PayPal our payment processing partner, according to the Payment Card Industry Security Standards.

    8.       How long we hold your information for

    Of the data we process outside of any contract we retain the data for no longer than is necessary. Where there is a legal requirement to retain data for longer than WICE requires (eg, Financial data must by stored for 7 years), we will do so. Where reasonably practicable data is minimised so not to be identifiable to the data subject unless required by law or is subject to a Subject Access Request.

    9.   Your rights

    You have various rights in respect of the personal information we hold about you – these are set out in more detail below.  If you wish to exercise any of these rights or make a complaint, you can do so by contacting us at the address at the top of the page:

    • Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing (includes email) and provide us with evidence of your identity at the time of making any request.
    • Right to object: You can object to our processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
    • Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time. Please contact us as noted above, providing notice that you have withdrawn your consent.
    • Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you. Please contact us as noted above, providing details of the inaccurate or incomplete information, what is required to correct the inaccuracy or to complete the information we hold about you.
    • Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Please contact us as noted above, providing details of the personal information about you that you wish to have deleted.
    • Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred. Please contact us as noted above, providing details of your objection.
    • Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it. Please contact us as noted above, providing details of the information you wish to restrict.
    • No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making, however we wish to advise you of all your rights even if they are not presently relevant to the processing WICE carries out.

    Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request. If we are unable to fulfil your request, then we will inform you as to the reason why.

    If you feel that the data protection team is not complying with the law, you can contact the WICE ombudsman at ombudsman@wice-paris.org  If you feel that WICE has an organisation has failed or is failing to  is not complying with data protection law you have the right to complain to the French Data Protection agency CNIL www.cnil.fr and can make a complaint at their website here Make a complaint to CNIL

    10.   Cookies

    'Cookie' is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit a website.

    They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, can't be used to identify you.

    How do we use cookies?

    We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you come to our website and also allows us to improve the user experience. 

    The cookies we use

    We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.

    We use all four categories of cookies:

    • Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
    • Performance cookies collect anonymous information about how you use our site, like which pages are visited most.
    • Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

    No cookies, please

    You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.

    But, if you choose to refuse all cookies, our website may not function for you as we would like it to.

    If you have any questions about how we use cookies, please contact the Data Protection Officer Please contact us as noted above

    11.   Monitoring

    Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.

    To find out more about this policy and how we look after your personal information, contact our data protection officer at dataprotection@wice-paris.org or on 01 45 66 75 50.

     


    WICE
    10 rue Tiphaine, 75015 Paris, France
    01 45 66 75 50  |  wice@wice-paris.org

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