This privacy notice explains how we look after your personal data (in all situations where we collect your data), sets out your privacy rights and explains how the law and our approach to privacy and personal data protects you.
This privacy notice supplements any other privacy notices that we may provide to you at the point that we collect data from you and should be read in conjunction with those notices.
For the purpose of the GDPR we are the data controller and any enquiry regarding the collection or processing of your data should be addressed to our Data Protection Officer using the contact details below:
Name: Aline Christen
Email address: firstname.lastname@example.org
Postal address: Rue de Chantepoulet 10, 1201 Geneva, Switzerland
By using the Website you consent to this policy.
We will collect, process and store personal data only if it is directly provided to us by you. You may do this in your capacity as the user of this Website, by enquiring in relation to our goods or services, becoming a member, customer or supplier, or potential supplier.
Personal information covers any information which relates to you as an identifiable person. Below are examples of the type of data that this may include:
We may also collect non-personal data such as Aggregated Data which is data that may be obtained from your personal data, but which does not directly or indirectly identify you. This may include Usage Data detailing how you use our Website and the features and areas that you have interacted with.
A range of different methods may be used to collect data which may include the following methods:
It is important that the data that we hold about you is accurate and up to date. In the event that your data changes please notify us so that we can update our records.
We may hold and process personal data that you provide to us in accordance with the GDPR.
The information that we collect and store relating to you is primarily used:
Where we collect your data for marketing purposes we will always request your consent, at the point the data is collected, to use your data for that purpose.
We will always obtain your prior consent to sharing your personal data with any third party for their marketing purposes. This may be to enable relevant third parties to advise you of products or services that may be of interest to you.
We will only use your personal data for a reason other than the purpose for which it was originally obtained if we consider that we need to use it for that other purpose and have a legitimate interest in doing so.
There are a range of circumstances where we may disclose your data to third parties. These include:
Please be advised that we do not reveal information about identifiable individuals to our advertisers/sponsors, but we may, on occasion, provide them with Aggregated Data about our Website visitors and customers.
If you do not want us to share your data with third parties you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data, or you can do so by writing to us at the address detailed above or sending us an email to email@example.com at any time.
Where we rely on consent as the lawful basis for processing your data you can revoke or vary that consent at any time.
If you do not want us to use your data or want to vary the consent that you have provided you can write to us at the address detailed above or sending us an email to firstname.lastname@example.org at any time.
As part of the services offered to you, for example through our Website, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating outside the EEA who work for one of our suppliers, e.g. our website server host, payment processing provider, membership management system provider or work for us when temporarily outside of the EEA.
A transfer of your personal data may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA.
If you use our service while you are outside the EEA, your personal data may be transferred outside the EEA in order to provide you with these services.
The transmission of information via the Internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site or email address; any such transmission is at your own risk.
We have put in place security measures to prevent your data from accidental, loss or disclosure. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Where you have chosen a password so that you can access certain parts of our site such as the members zone, you are responsible for keeping this password confidential. You should choose a password that is difficult for someone to guess. ESRA does not have access to your personal password and cannot retrieve it for you. Should you need a new password, you can contact ESRA by email and we will send you a link to update your password
In the event of a data breach we will notify you in the event that the breach results in any likelihood of loss or damage to you.
The length of time that we retain, and store data depends on the purpose for which it was collected. We will only store data for as long as is required to fulfil that purpose, or for the purpose of satisfying legal requirements.
It is a legal requirement that we keep certain data about our customers and suppliers for at least six years. The type of data includes Contact, Identity, Financial and Transaction Data.
Where you have requested that we provide you with marketing materials we will retain your data until such time as consent is withdrawn by you.
We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and the service that we provide to you.
The GDPR gives you a range of rights in relation to the personal data that we collect from. You have the right to:
You can exercise these rights at any time by writing to us at the address detailed above, or by email to email@example.com
You might find links to third party websites on our website. If you click a link to a third-party website and visit that site, you may be allowing that site to collect and share certain data about you. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
If you wish to raise a complaint regarding our use of your personal data then you can contact your national data protection authority.
If you do wish to raise a complain then we would welcome the opportunity to discuss your concerns before you contact your national data protection authority to see if we can resolve the issue for you.
We may update these policies to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.
Version: May 2018