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Privacy Policy
Eurapco Privacy and Personal Data Processing Policy
1. Processing of personal data in Eurapco
We consider the careful and safe handling of personal data to be of prime importance. When processing personal data, we comply with the applicable legislation and we follow good data management and processing practices. We take measures to ensure that the privacy and other fundamental rights of our stakeholders are assured.
2. What personal data do we collect?
We collect only the data that is appropriate, necessary and relevant for the purpose of the business. The type of data collected from each stakeholder in a certain situation is determined by the purpose of the service offered. By stakeholders we mean mainly Eurapco Partners’ employees, but also third parties, consultants, keynote speakers and any other suppliers providing us services which support our business model and activities.
We may collect data such as:
- Name
- Company name
- Address
- Postal code
- Country
- City
- Social media
- Gender
- Birthday
- Phone number
- Picture
- Job position
- Skills and experience
- Professional memberships
- Dietary preferences
- Data on choices made by the stakeholder, such as consents, restrictions or refusals related to the use of personal data
- Other types of data that is voluntarily sent to Eurapco without any specific request
3. Where do we collect personal data?
We collect personal data primarily from employees of the Eurapco Partners in connection to Eurapco activities. We also receive data about our stakeholders when they participate in campaigns and surveys, log in to our application or when they register on e-join, our collaboration platform. We also receive data from participants in educational programmes offered by the Eurapco Academy. We also receive data from the Eurapco Alliance Partners companies, including their affiliates, subsidiaries and other entities, which includes data about their employees. Stakeholder data is also collected using cookies.
4. For what purposes do we collect data?
We collect, store and process our stakeholders’ personal data only for predefined purposes of use. Our purpose as a knowledge exchange facilitator is not to commercialise the personal data but rather to help our Partners to work in a more efficient manner. Stakeholders that want to receive more information about our legitimate interests can ask for more information contacting info@eurapco.com. We use personal data for the following purposes:
- We collect general information about the Eurapco Partner employees that we have received from our Partner companies to communicate with our Partner employees, facilitate communication between our Partners and to identify our stakeholders. The collected data consists of contact details in case that the individuals do not provide more information by themselves.
- Once a Eurapco Partner employee submits a registration form to a Eurapco activity that information is processed to/for a) organise the logistics (e.g. hotel) of the activity, b) update the Eurapco Partner employees about any changes to the activity and to provide them with the necessary information regarding the activity, c) personalise the event for the participants (e.g. name badges) in order to make the event participation friendlier, d) collaboration purposes in working groups and projects (e.g. providing the Eurapco Partner employees with information regarding projects), e) execute post event communications; f) take into account dietary preferences.
- The registration information is processed to send the invitations and to engage the participants to the communication platform that is used as a part of Eurapco activities.
- Our third party service providers will retain data, including cookies, about the visits to our website/applications on behalf of us in order to create analytical information for us about how our website visitors/application users use our website/applications. Our third party service providers provide the data to us in an aggregated anonymised form.
- We collect participant evaluation forms at the end of our activities to develop and improve our activities and to measure the satisfaction levels.
- Once a Eurapco Partner employee submits an application to the Eurapco Academy we collect the information to decide whether the Eurapco Partner employee is accepted to the programme or not. We may also consult the human resources of the specific Partner company and send the application to them.
- We collect data about the participants of the Eurapco activities in order to maintain our Alumni network and maintain communications.
- We collect information about presentations and other types of documents that may include personal data that were presented in a Eurapco activity in order to identify the source of the data, highlight/report the successfulness of the Eurapco activities and to provide a possibility for the participants to see what was presented in a Eurapco activity.
- We take sometimes pictures/videos in order to create content for our collaboration platform e-join and to have “memories” of the Eurapco activities. We also store the pictures/videos to demonstrate Eurapco highlights. The data is also processed to create anniversary publications and Eurapco newsletter publications. Additionally, the data is used for archiving purposes in order to store the data in a more secure manner.
- We collect and retain records that we are obliged to keep according to the applicable law in order to fulfil our legal obligations.
- Once a Eurapco Partner employee creates an account for a Eurapco application that information is being processed to deliver the access to the platform and to send push notifications/newsletters to the users of the application.
5. Legal bases for processing
According to the General Data Protection Regulation we always have to have a legal ground to process your personal data. We will rely on the following legal bases once we process your personal data:
- Eurapco processes personal data in order to fulfil its legal obligations.
- Eurapco processes personal data when the processing is necessary for a performance of a contract.
- Eurapco processes personal data when you have given your consent.
- Eurapco processes personal data when it has a legitimate interest. The legitimate interests of Eurapco include the following interests:
A) Eurapco’s legitimate interest is to identify its stakeholders and to facilitate communication/collaboration between its Partners.
B) Eurapco’s legitimate interest is to deliver interesting and attractive Eurapco activities and involve as many people in the Eurapco activities as possible.
C) Eurapco’s legitimate interest is to highlight, demonstrate and report the successful projects that have occurred as part of the Eurapco activities and to get relevant information about the older projects and activities that Eurapco can use in current/future projects.
D) Eurapco’s legitimate interest is to store data to make presentations, newsletter publications and anniversary publications as attractive as possible.
E) Eurapco’s legitimate interest is to make Eurapco activities as participation friendly as possible and to provide the best possible service.
F) Eurapco’s legitimate interest is to maintain Eurapco’s collaboration platform functional and attractive and to create value for its Partners.
G) Eurapco’s legitimate interest is to improve the user experience of its website and applications as well as improve and develop Eurapco activities.
H) Eurapco’s legitimate interest is to avoid misunderstandings among the participants of the Eurapco activities and to identify the participants on a project-based level.
I) Eurapco’s legitimate interest is to facilitate its everyday business activities, secure the effective functioning of its projects/activities and to implement appropriate security measures.
6. Who processes the personal data and to whom is the data disclosed to?
Eurapco Partner companies may consult and process our stakeholders’ personal data in accordance with the current data protection legislation. Access to personal data is granted only to Eurapco employees on a need to know basis. The data may be disclosed also to our third party service providers who perform IT maintenance/support services and process the data for archiving purposes on behalf of us. Our IT third party service providers may also collect/have access to personal data when they create analytics for us. If we are obliged by law to transfer personal data, for example to authorities, we will comply with such a request.
7. How long is the data stored?
Eurapco processes personal data for various purposes. Regardless of the manner by which we receive or collect the data we always take the following factors into account when considering the retention periods of personal data a) Is the personal data necessary to us?; b) What are the possible negative consequences for the data subjects that may be born out of the processing?; c) Do we have a legal obligation to store the data?; d) How sensible the data is for the data subject?; and e) Is it possible to delete the personal data earlier than defined in the retention schedule? Once the retention period has lapsed we will delete the data from all our systems in a secure manner. We have designated a responsible person for the deletion of personal data who takes care that the data is deleted securely and according to the defined retention periods.
Data | Retention period |
---|---|
Records that we are obliged to keep according to law |
As defined by law |
Presentations and other documents |
15 years (If we are not under a legal obligation to store the documents longer.) |
Records of Eurapco Alumnis |
The data will be removed after 5 years have lapsed from the last participation of the Alumni to an Alumni activity. |
Applications/registration forms |
Deleted after a reasonable time has lapsed after the application process (approximately 1 year). |
Pictures/videos |
Maximum 25 years (not all photos/videos are stored this long) |
Evaluation forms |
18 months |
Login information to our applications |
As long as a person does not delete his/her account. |
Stakeholder data (contact details and other similar information) |
As long as a Eurapco Partner employee works in a Partner company. |
Information regarding dietary preferences |
1 month |
8. Image capture
Images may be captured during events hosted or organised by Eurapco using photography, video or other medium. These images may be used on the Eurapco website, for newsletter publications, and for internal and external materials, such as presentations. Eurapco informs all participants taking part in events that they may be photographed or filmed during the registration process. Objections to being captured on image, should be raised with the host or the photographer present at the event. Eurapco will respect any such objections by not photographing/videotaping those individuals as a prove of good practice.
9. Information security
To protect personal data, we use technical and organisational information security measures in line with necessity and best practices. All the suppliers we work with are responsible for personal data storage and their systems have been audited or otherwise inspected.
Personal data is secured in such a way that accessing, disclosing, destroying or other processing is done appropriately and only by persons with the right to carry out the activities.
The protection of personal data is safeguarded for example with firewalls, different cryptographic techniques, and by ensuring the safety and appropriate access control of the equipment rooms. Appropriate access to personal data is ensured through access management processes, and access is granted based on work assignment and job role.
The processing of personal data is monitored for example by logging. Logs reveal what, why and when something occurred. Logs are used to investigate errors or to make sure that errors have not occurred and that the processed data is accurate. Staff participating in the processing of personal data are trained and instructed regularly. The operations of our suppliers are also regularly inspected and audited.
10. Push messaging
The activation of the Eurapco Push Messaging Service is voluntary and implies that all notices considered of interest to users (e.g. new posts, likes on users’ posts and/or users’ comments, comments on users’ posts and/or comments on a post users have commented on) will be sent through the notifications service of the operating system of the device. The app only sends out push messages if the user expressly agreed to them. Users can view them from the message box within the application and they can also be found in the notification center.
All Eurapco messaging using this notification system is free. In order for users to receive messages, they must have access to the Internet. Users should keep this in mind if they disconnect data by roaming when travelling abroad.
When users register the device from which they are subscribing to the push notification system, Eurapco will be authorised to use these notifications for the purposes authorised in the use of the application. The user can deactivate the sending of push notifications in the app settings or in the device settings and revoke his/her consent at any time.
11. Possible consequences of the processing
Eurapco does not process personal data that could cause major risks for the individuals. Eurapco processes mainly contact details of the Partner employees and that data does not include confidential data that would likely result in high risks to the individuals. The risks that relate to the processing can be generally deemed as low.
12. How to impact the processing of personal data
Data protection legislation aims at protecting the fundamental rights of the individuals. The protection of personal data from unauthorised or detrimental usage is the basic principle of data protection.
We offer our stakeholders opportunities to decide and to control the processing of their own personal data. Listed below are ways in which our stakeholders can impact the collection and processing of their personal data.
13. Email communications
Stakeholders have the right to refuse the use of their personal data in direct communications, newsletters, marketing campaigns, and opinion surveys at any time. Stakeholders may decide to what extent or for which parts they wish to exercise this right. Exercising this right is free of charge.
Stakeholders can file a communications prohibition by announcing it to Eurapco either by emailing info@eurapco.com or by mail to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
Stakeholders can also unsubscribe from receiving electronic direct communications by following this link: https://apps.eurapco.com/unsubscribe . The link is always included in all Eurapco communication and newsletters.
14. Right of access
Our stakeholders have the right of access to data that Eurapco is processing about them. The stakeholder must report details needed for the search and delivery of the data. Such details include, for example, the name, the email address, what topic or issue the data requested is related to, whether data is requested for a certain time period or whether the right of access is exercised on all data. Exercising this right is free of charge. We must reply within a month to your request.
Stakeholders can make an access request for example by emailing info@eurapco.com or sending a signed request for verification in writing to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
15. Right to rectification
We strive to ensure the currency and accuracy of our stakeholder data by constantly keeping our systems up to date. Stakeholders have the right to demand that registered personal data found erroneous or insufficient in terms of processing to be rectified. The data must concern the requesting stakeholder themselves. The more justifiable, specified and clear the request for correction is, the better we can process it. Exercising this right is free of charge. We must reply within a month to your request.
Stakeholders can make a rectification request for example by emailing info@eurapco.com or sending a signed request for verification in writing to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
We will either correct inaccurate or insufficient personal data upon request of the stakeholder or else return a certificate of refusal in writing containing the reasons for why the correction request was not accepted. If we have submitted the data to third parties, we will inform them of the correction of the data.
16. Right to be forgotten
Stakeholders have the right to request, subject to certain exceptions, that data concerning them is removed from our systems. This does not mean that all personal data must be removed immediately and definitively after a demand has been made. If data storing is necessary for example due to a legal obligation the data may be stored for such a purpose for as long as is necessary. The removal of personal data will always be decided on a case-specific basis. Exercising this right is free of charge. We must reply within a month to your request.
Stakeholders can make an erasure request for example by emailing info@eurapco.com or sending a signed request for verification in writing to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
The request should contain at least the full name of the stakeholder and email address or phone number as well as what data the stakeholder wants that we erase.
17. Right to object
Stakeholders have the right to object the processing of personal data. This right applies only in certain circumstances. If there are no grounds to refuse a stakeholder’s request Eurapco must stop the processing of the personal data. Stakeholders must give specific reasons why they want to object the processing of their personal data. Exercising this right is free of charge. We must reply within a month to your request.
Stakeholders can object the processing for example by emailing info@eurapco.com or sending a signed request for verification in writing to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
18. Right to restrict processing
Stakeholders have the right to request that the processing of their personal data is restricted in some circumstances. Exercising this right is free of charge. We must reply within a month to your request. You can request us to restrict the processing of your personal data, for example, by emailing info@eurapco.com or sending a signed request for verification in writing to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
19. Right to data portability
You have a right to receive a copy of your personal data and/or have your personal data transmitted from our systems to another controller in some circumstances. The right applies only to the information that you have personally submitted to us and only when we are carrying the processing by automated means and we rely on consent as our legal basis or when the processing is necessary for a performance of a contract. Exercising this right is free of charge. We must reply within a month to your request.
Stakeholders can make a data portability request for example by emailing info@eurapco.com or sending a signed request for verification in writing to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
20. Right to lodge a complaint to a supervisory authority
Stakeholders have a right to lodge a complaint to a supervisory authority if they believe that we do not comply with the General Data Protection Regulation when we process their personal data. Stakeholders can complain to the supervisory authority of the EU country in which they either work or reside.
21. Right to withdraw consent
Stakeholders have the right to withdraw their consent when we have relied on consent as our lawful ground. Stakeholders are allowed to withdraw their consent always. Stakeholders can withdraw their consent, for example, by sending an email to info@eurapco.com or sending a signed withdrawal request for verification in writing to the following address:
European Alliance Partners Company AG
Elias-Canetti-Strasse 2
CH-8050 Zurich-Oerlikon
Switzerland
22. Data transfers outside the EU
The data is either processed in the European Union or Switzerland. The data transfer to Switzerland is based on the adequacy decision that the European Commission has given under Article 45 of the General Data Protection Regulation.
Specific information regarding e-join
23. Data Collection concerning e-join
All Eurapco Partner employees have the possibility to create an e-join account. By registering on e-join, they can provide their photo, full name, email address, contact information, job information, company information and other additional information that they are willing to share.
The personal data entered by e-join members is collected, stored and used exclusively for the use of the e-join platform. This data is visible and accessible by any active member in the platform. Some groups are restricted and only certain individuals have access to them.
Any content posted and uploaded by e-join members can be identified with the profile of that person. Content and contributions shared by e-join members belong to Eurapco and will not be removed by Eurapco unless data is non-compliant or sensitive to the individuals. Members can always delete their own contributions to the collaboration platform by themselves.
Personal data provided by e-join members is never shared with third parties unless there is a statutory obligation from authorities. The e-join members are prohibited to distribute the material uploaded to e-join outside the platform.
24. Removal of data from e-join
Any e-join member can request to deactivate their account at any time by sending an email to info@eurapco.com. Their account will be listed as inactive on the platform, but their content and contributions will remain stored on the platform for business purposes.
Members that have not logged in for 12 months will receive an automatic notification to inform them about the deactivation of their account. Unless they take action to log-in to the platform, their account will be made inactive. Inactive members who do not wish for their content and contributions to be associated with their personal profile can request for this information to be anonymised. This process is not standard by default, but available upon special request. E-join members can request content anonymisation by contacting info@eurapco.com. If there is a legal obligation to remove the account, we will comply with such an obligation.
25. Additional information
European Alliance Partners Company AG is the controller for the processing of data under this policy. Current version is 1.6.
This policy can be adapted & changed from time to time. Once we update our privacy notice we will notify you about it on our website in a clear and transparent way.
If you have any questions regarding the processing of personal data and information security you can contact us by sending an email to info@eurapco.com.