For the purpose of this Privacy Notice, “Data Protection Legislation” means: (i) the UK’s Data Protection Act 2018, as applicable; (ii) the General Data Protection Regulation 2016/679 (the “GDPR”) until the Data Protection Act 2018 replaces the GDPR; and (ii) then the Data Protection Act 2018 and any other applicable UK data protection legislation.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of Data Protection Legislation, the data controller is the Spanish Chamber of Commerce in the United Kingdom Limited (“SCC”, “us”, “our” or “we”). Our data controller registration number is Z1574779. We will treat your personal data in accordance with our obligations under Data Protection Legislation and implement adequate security measures. Our aim is to be clear and transparent about the way we use your personal data and not do anything you would not reasonably expect.
By using the website www.spanishchamber.co.uk (the “Website”) or submitting personal data to us, you signify your consent to our collection, use and disclosure of your personal data in accordance with this Privacy Notice. If you do not agree with this Privacy Notice, you must not use the Website or submit personal data to us through or in connection with the Website or otherwise.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1. PERSONAL DATA WE MAY COLLECT FROM YOU
1.1 We may collect the following personal data:
(a) personal data contained in any business information that you submit to us such as contact person and position within your company, email addresses or mobile numbers;
(b) personal data that you provide by filling in forms and submitting information over the phone, by post, email, fax or on the Website. This includes personal data provided on registration, subscribing to any one of our services, through surveys, by posting material on the Website or by requesting services from us. The above information may include any personal data that relates to and identifies you, including but not limited to your name, postal address, e-mail address, telephone number, bank account details, and any other information collected;
(c) the SCC may check some of the information that you provide against third party databases to confirm that it is accurate;
(d) if you contact us, whether through the Website or otherwise (for example, by post, email, fax, phone, text message) we may keep a record of that correspondence or call. For example, if you submit a query, a complaint or a refund request, report a problem with our service or Website, or otherwise liaise with our customer service, technical support or any other department within the SCC, we may keep such record;
(e) we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
(f) your IP address (this is your computer’s individual identification number for internet connection) is automatically logged by our web server. This is used to note your interest in this Website;
(g) details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access); and
(h) if you submit your Curriculum Vitae (“CV”) to us or you post your CV in the career services area of our Website.
2. HOW WE MAY USE THE PERSONAL DATA COLLECTED FROM YOU
2.1 We may process this personal data for the purpose of:
(a) informing you about services provided and events organised by the SCC that may be of interest to you. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests;
(b) administering registration and membership records (including membership reminders, e.g. update your payment details). Lawful Basis: to comply with our legal obligations, performance of our contract with you or necessary for our legitimate interests;
(c) providing you with information about special features on the Website or any special services or products or related information from third parties, which we believe may be of interest to you. Lawful Basis: your consent or necessary for our legitimate interests;
(d) providing and personalising our products or services. In some circumstances the SCC’s records may identify representatives of organisations visiting the Website and the SCC may use that personal data in managing its relationship with those organisations. Lawful Basis: your consent or performance of our contract with you or necessary for our legitimate interests;
(e) providing you access to all parts or features of our services or the Website. The SCC may monitor visits to the Website, in order principally, to ensure that it is easy to navigate, identify the areas that are of particular interest to visitors and generally improve the Website and services offered. Lawful Basis: to comply with our legal obligations, performance of our contract with you or necessary for our legitimate interests;
(f) ensuring that content from our Website is presented in the most effective manner for you and for your computer or mobile device. Lawful Basis: necessary for our legitimate interests;
(g) communicating with you on any matter relating to the provision of the SCC services, dealing with your inquiries and requests, including contacting you if necessary. Lawful Basis: to comply with our legal obligations, performance of our contract with you or necessary for our legitimate interests;
(h) carrying out our obligations arising from any contracts entered into between you and us. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
(i) processing your payment or payment from your company. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
(j) contacting you for your views on our services and notifying you occasionally about important changes or developments to our services or the Website. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
(k) notifying you about changes to our services. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
(l) carrying out market research campaigns. Lawful Basis: your consent or necessary for our legitimate interests;
(m) organising events with other Chambers or organisations. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
(n) enabling the SCC and third party companies to access the CV you submitted to us in relation to job opportunities. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests; and
(o) informing you of any service provided by a third party that may be of interest to you. Lawful Basis: your consent or necessary for our legitimate interests.
2.2 We may also use your personal data to provide you with information about goods and services which may be of interest to you and we may contact you about these by email, post or telephone. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests.
2.3 We may also gather this information and statistics for the purposes of monitoring the usage of the Website and our services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify you.
2.4 If you stop using our services or the Website, or your permission to use the Website or our services is terminated, we may continue to use and disclose your personal data in accordance with this Privacy Notice (as amended from time to time) and as permitted by law. However, if you wish us to stop e-mailing you, please send your request to firstname.lastname@example.org.
3. TO WHOM WILL YOUR PERSONAL DATA BE DISCLOSED?
3.1 Your personal data may, for the purposes set out in this Privacy Notice, be disclosed for processing:
(a) to our patrons, partners, members, (including prospective patrons, partners or members) in the context of the SCC activities as a chamber of commerce. For instance, the information you have posted on the members account of our Website. In limited circumstances, we may disclose the contact details of the representative of a member to another member in the context of the SCC activities as a chamber of commerce;
(b) to selected third parties who may be interested in the products or services of the business you represent;
(c) to regulatory bodies for the purposes of monitoring and/or enforcing our compliance with any regulatory rules/codes or where required by law, regulation or legal proceedings;
(d) to a competent authority in response to a valid, legally compliant request by a competent authority;
(e) to other chambers of commerce, the Spanish embassy or other organisations with similar aims and objectives in the context of the SCC activities as a chamber of commerce;
(f) to our employees;
(g) if you use our Website’s job search facility, your CV will be posted and accessible to the public on the career services area of our Website. We may also share your CV with companies who might be interested in your profile in the event of a job vacancies;
(h) to third parties from whom you have chosen to receive marketing information;
(i) to auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;
(k) to third party consultants, contractors or other service providers who may access your personal data when providing services to us (including but not limited to IT support services).
4. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
4.1 Please note that these rights do not apply in all circumstances. You are entitled to:
(a) request access to your personal data (commonly known as a “data subject access request”);
(b) request correction of the personal data that we hold about you;
(c) request erasure of your personal data. 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;
(d) 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 particular 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 personal data which override your rights and freedoms;
(e) 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:
(i) if you want us to establish the data’s accuracy;
(ii) where our use of the data is unlawful, but you do not want us to erase it;
(iii) 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; or
(iv) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it;
(f) 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 (i.e. not to hard copies) which you initially provided consent for us to use or where we used the information to perform a contract with you; and
(g) withdraw consent at any time where we are relying on consent to process your personal data. 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. Please write to: 126 Wigmore Street, London, W1U 3RZ or email@example.com.
4.2 Please quote your name and address. We should be grateful if you would also provide brief details of the data that you would like a copy of or which you would like to be corrected (this helps us to more readily locate your data).
4.3 We will require proof of your identity before providing you with details of any personal data we may hold about you.
4.4 If you wish to do this, please write to: 126 Wigmore Street, London, W1U 3RZ or firstname.lastname@example.org. Please quote your name and address in any such correspondence. Please also provide brief details of the information of which you would like a copy or which you would like to be corrected, if possible (this helps us to more readily locate your data).
4.5 We try to respond to all legitimate requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request and keep you updated.
4.6 We will require proof of your identity before providing you with details of any personal data we may hold about you. We may charge a reasonable fee from you or reject a request when a request is manifestly unfounded or excessive or repetitive or we receive a request to provide further copies of the same information.
5. INFORMATION SECURITY
5.1 The internet is not a secure medium. However, we have put in place various security procedures with regards to the Website and your electronic communications with us, as set out in this policy.
5.2 Please be aware that communications over the internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
5.3 Where you have been allocated a user admin area (an “Account”), this area is protected by your user name and password, which you should never divulge to anyone else. You are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.4 We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
5.5 All of our employees and data processors that have access to, and are associated with, the processing of your personal data are obliged to respect the confidentiality of our visitors’ information.
5.6 We may need to disclose your data, if required by law or when requested to by regulatory bodies or law enforcement organisations, which may use your data for regulatory purposes.
7. YOUR CONSENT AND CHANGES TO THIS PRIVACY NOTICE
7.1 By submitting any personal data to us, you consent to the use of information as set out in this Privacy Notice. We reserve the right to amend or modify this Privacy Notice and if we do so we will post the changes on the Website. It is your responsibility to check the Privacy Notice every time you submit information to us or place an order. Use will signify that you agree to any such changes.
7.2 In the event the purposes for processing your personal data change, we will contact you as soon as practicable and seek your consent for the new purposes where such new purposes relate to a new additional purpose for processing which is not compatible or similar to the originally specified purposes.
8 WHERE WE STORE AND PROCESS YOUR PERSONAL DATA
8.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or affiliates. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. By way of example, we may implement one of the following safeguards for personal data transfers outside the EEA:
(a) Only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
(b) Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
(c) Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
9 USE OF YOUR PERSONAL DATA SUBMITTED TO OTHER WEBSITES
9.2 We are not responsible for the privacy policies and practices of other sites even if you accessed the third party website using links from our Website.
9.3 We recommend that you check the policy of each site you visit and contact the owner or operator of such site if you have concerns or questions.
10 DATA RETENTION
10.1 We will only retain your personal data for as long as you have consented to it or when is necessary to us to provide you with our services or fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For instance, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) typically for six years after they cease being customers for tax purposes.
10.2 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 requirements.
10.3 In some circumstances you can ask us to delete your personal data.
10.4 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
11.1 If you have any questions about the SCC’s Privacy Notice, you think that the information it holds about you may need to be corrected, or you would like us to provide you with information about our services or services offered jointly with or on behalf of other organisations, please send an email to email@example.com or write to us to 126 Wigmore Street, London W1U 3RZ.
11.2 You can also contact the Information Commissioner’s Office if you have a complaint regarding your personal data that we cannot resolve. Their website address is: https://ico.org.uk/
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