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Privacy Policy 1.2

22 May 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 ask us about our activities, register with us for a course or an event, make a donation 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, make a purchase from our shops or website, or get in touch through the post, or in person.

When you visit our website: We gather general information which might include the pages you visit most often and which services, events or information is of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use "cookies" to help our site run effectively. There are more details below – see 'Cookies'.

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 making a donation, registering for an event or course on our website or any of the other ways to interact with us.

We will use this information:

  • To process your donations or other payments and verify any financial transactions.
  • To provide the services (courses and events) that you have requested.
  • To update you with important administrative messages about your donation, an event or services you have requested.
  • To keep a record of your relationship with us.
  • Where you volunteer with us, to administer the volunteering arrangement.

If you do not provide this information, we will not be able to process your donation, sign you up for an event, provide any goods and services you have requested, or effectively administer your membership the volunteering arrangement that you have entered into with us. This will make it impossible for you to remain a member of WICE.

We may also use your personal information:

  • To contact you about our events and courses and how you can support WICE (see section 8 on 'Marketing' below for further information).
  • To invite you to participate in surveys or research.

4.       Legal basis for using your information

We will only use your personal information where we have your consent or because we need to use it to fulfil a contract with you (for example, because you have registered for an event on our website).

However, there are other lawful reasons that allow us to process your personal information and one of those is called 'legitimate interests'. This means that the reason that we are processing information is because there is a legitimate interest for WICE to process your information to help us to provide a better service, to ensure you are provided with the services you have paid for and for legal compliance.

If you are a member of WICE we need to hold some personal data so that we can manage your membership and give you access to the full range of services.  We will hold this data under the legitimate interest. All the data we hold on a member can be viewed on the members account page. If your membership lapses and we do not have consent to hold your personal data, your data will be deleted.

We will also hold limited personal data on non-members if they are attending one of our events, we need to hold this data so that we can manage your attendance. Once the event is complete if we do not have consent to hold your data, your personal data will be deleted.

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.

Some examples of where we have a legitimate interest to process your Personal Information are where we contact you about our work via post, conducting research to better understand who our members are, improving our services, for our legal purposes (for example, dealing with complaints and claims), or for complying with the law.

5.       Marketing

We will only contact you about our organisation, our aims and courses that we think you will be interested in and how you can support WICE by phone or email if you have agreed for us to contact you in this manner.

However, 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.

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 of these individuals will be required to undertake data protection training and agree to the WICE privacy guidelines.

We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.

Legal disclosure

We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.

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

We only keep it as long as is reasonable and necessary for the relevant activity while you remain a member. We may also store your information for a reasonable time after you have ceased being a member  (3 months) to allow you to re-join with ease and to fulfil our legal obligations.

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

Association régie par la loi du 1er juillet 1901
N° Siret 380 703 595 00039
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