Last updated: 28 April 2021
1. About this Notice
1.1. This Privacy Notice (“Notice”) explains how we (as defined below) collect, share and use any information that, alone or in combination with other information, relates to you (“Personal Data”) when you (“you” and “your”) use our website [http://188.8.131.52/] (the “Website”).
1.2. This Notice also sets out the rights that you have in relation to the Personal Data that we process about you and how you can exercise them.
1.3. PES treats compliance with its privacy obligations seriously. This is why we have developed this Notice, which describes the standards that PES applies to protect Personal Data.
1.4. For the purposes of this Notice, PES, an international non-profit association registered under the name of PSE aisbl, with registered office at Guimardstraat 10-12 and registered with the Crossroads Bank of Enterprises under number 0897.208.032, (“we”, “us” or “our” ) acts as the data controller for the Personal Data that is collected via the Website. As a data controller, PES is responsible for ensuring that the processing of Personal Data complies with applicable data protection law, and specifically with the General Data Protection Regulation.
1.5. Please take the time to read this Notice carefully. If you have any questions or comments, please contact us via [email protected]
2. What Personal Data does PES collect and why?
2.1. The PES may collect certain information automatically from your device. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
We collect this information for the purposes of this Notice, including to enable us to better understand the visitors who come to our Website, where they come from, what content on our Website is of interest to them and to set up a statistical database. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further in our Cookie Notice.
2.3. From time to time, we may receive Personal Data about you from third-party sources (social media including Facebook, if you have subscribed to our newsletter there or if you have completed one of our Quizzes in Facebook), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us.
The types of Personal Data we collect from third parties include Identification Data and Location data and we use this Personal Data we receive from these third parties to maintain and improve the accuracy of the records we hold about you.
2.4. In general, we will use the Personal Data we collect from you only for the purposes described in this Notice or for purposes that we explain to you at the time we collect your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
3. Who does PES share your Personal Data with?
3.1. We may disclose your Personal Data to the following categories of recipients:
(a) to our third-party vendors, services providers, and partners who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Notice or notified to you when we collect your Personal Data. This may include disclosures to third party vendors and other service providers we use in connection with the services they provide to us, including to support us in areas such as IT platform management or support services, infrastructure and application services, marketing, data analytics;
(b) to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
(c) to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose;
(d) to any other person if you have provided your prior consent to the disclosure.
4. How we protect your privacy
4.1. We will process Personal Data in accordance with this Notice, as follows
(a) Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law.
(b) Purpose limitation: We will process Personal Data for specified and lawful purposes, and will not process it in a manner that is incompatible with those purposes.
(c) Proportionality: We will process Personal Data in a way that is proportionate to the purposes which the processing is intended to achieve.
(d) Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us promptly of any changes or errors. You should notify us of any changes to the Personal Data that we hold about you (e.g. a change of address).
(e) Data security: We use appropriate technical and organisational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
(f) Data processors: We may engage third parties to process Personal Data for and on behalf of PES. We require such data processors to process Personal Data and act strictly on our instructions and to take appropriate steps to ensure that Personal Data remains protected.
(g) International data transfers: Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. Specifically, our servers are located in the EU, and our third-party service providers also operate in the EU and the US. This means that when we collect your Personal Data we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Data with our third party service providers and partners. Further details can be provided upon request.
(h) Data Retention: We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
5. Your data protection rights
5.1. You have the following data protection rights:
(a) If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the following contact details: [email protected]
(b) In addition, in certain circumstances, as stipulated in the applicable data protection legislation, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the following contact details: [email protected]
(c) If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
(d) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided above.
(e) If you have a complaint or concern about how we are processing your Personal Data then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here)
5.2. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
6. Linking to other websites
6.1. The Website may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of Personal Data you submit whilst visiting these websites.
We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
7. Updates to this Notice
7.1. We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws.
7.2. You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.