Director General, EACA, Europe
We are committed to ensure the protection of your Personal Data and your privacy.
VoxComm is part of EACA, the “European Association of Communications Agencies”, with its business address at 120, Avenue Louise, 1050 Brussels. It is registered in Brussels under the number BE 0422.332.060.
VoxComm strives to represent national and/or regional agency associations globally. In order to achieve its objectives the organisation intends to, among other activities, organise up to four virtual or physical meetings every year, set up a website to promote the organisation, its members and its activities to the public, as well as providing useful information to members.
(i) for the Membership and outreach – see Section I: “Data processing in connection with Membership & outreach”
(ii) via our Website – see Section II: “Data processing in connection with our Website”
Data processing that is common to all sections is grouped under the section V: “Common provisions”.
About the terms used
We use any of the terms “we”, “us”, and “our” to refer to EACA and/or VoxComm.
We use the terms “Parties” to refer to you and us.
SECTION I: Data Processing in connection with Membership (EACA & VoxComm), and Outreach
The purpose of this Section is to inform you about how EACA/VoxComm processes the personal data of applicant EACA/VoxComm Member Organisations’ contact persons (hereinafter, “Personal Contact Data”) within the scope of membership and in the course of our outreach activities. The following is a description of the various data processing operations, in which you may possibly be involved.
As between the Parties, the member is the data controller of all data provided by the member to us and the member has the right to direct us in connection with processing of such data. Notwithstanding the foregoing, we are data controller for all data that are provided by us to a member during the membership. Each party shall fully comply with its obligations as data controller under the applicable laws in this respect.
Each Party consents that the other Party, in the context of or in connection with membership and outreach, collects, processes, stores, communicates or archives Personal Contact Data (e.g. names, e-mail addresses, position, physical address and telephone numbers), but only to the extent that such collection, processing, storage, communication or archiving will be necessary to perform the membership and/or outreach activities such as inviting you to events, informing you of our meetings, invoicing our members, etc.
Each Party shall ensure that any disclosure of Personal Contact Data made by it to the other Party is made with the data subject’s consent or is otherwise lawful.
1.1. The Personal Contact Data collected when you register as a member.
EACA/VoxComm processes the Personal Contact Data for the purpose of entering into a contract with the respective applicant EACA/ VoxComm Member Organisation (“Membership”).
The legal basis for such processing is the contractual necessity.
1.2. When you register for a meeting or a video conference
EACA/ VoxComm will be sending invitations to meetings, video conferences, and communications related to EACA/ VoxComm events and meetings.
The legal basis for such processing is the contractual necessity.
When you decide to participate in one of our meetings or events, your data enables us to organize the event. In certain cases, the data may also be communicated to third parties linked to the organisation of the event (e.g. hotel if you book a room through us, or restaurant for your dietary preferences, etc.).
When you decide to participate in one of our videoconferences, we will inform you upfront whether the conference will be recorded for the purpose of making available the recording to members only. By registering for the video conference you expressly consent that you may be recorded.
We may use pictures and videos of you taken during events and post them on our website. Such processing is based on our legitimate interest to promote our activities. If you have a valid reason to object to our legitimate interest, we ask you to contact us and we will then no longer use your personal data in new information material. We will also remove you from already published material wherever possible and/or modify the material so you cannot be identified any longer.
1.3. When you receive questionnaire and /or surveys from us
Based on our legitimate interests consisting in improving our services to our members, we may send you questionnaires and/or surveys after a meeting or a video conference. Based on contractual necessity, we may send you questionnaires and/or surveys to enquire about your opinion about certain topics covered in our work.
Responses to these questionnaires will remain confidential and will not be shared with the public, unless we have all members’ express consent. However, we reserve the right to aggregate all the data received from our members in a non-identifiable manner and to share it with participating members, to enable us to offer benchmarking services to our members or to use the data, including copying, transforming, creating meta-data and generally to take any action on the data that we believe would be useful or in the interest of our members.
Google Docs/Forms/Drive under general Google policy
1.4. How does EACA/VoxComm store personal data and who can access it?
EACA/VoxComm maintains an automated record of each Member’s data. This automated record contains most of the data held in the Member’s file. Additionally, EACA/VoxComm maintains data in various digital documents, namely event attendee lists and meeting records and minutes.
The persons and entities that can have access to your data are:
• All EACA/VoxComm staff based in the offices in Brussels;
• External professional services, such as IT systems providers (EACA/VoxComm online domain/website hosting supplier, its database software supplier);
• In the case of event organisation, the co-organiser and event agency for the sole purpose of organising an event you have registered to;
Third party service providers, as our processors, only hold and use data on our behalf in order to provide us with a service. We may also disclose personal data to our professional advisors and experts in order to obtain their assistance in carrying out our services and our activities.
Where EACA/VoxComm engages a third-party processor to process data on its behalf, such as those listed above, EACA/VoxComm will delegate such processing in writing, will choose a processor that provides sufficient guarantees with respect to technical and organisational security measures governing the relevant processing, and will obligate the processor to act on EACA/ VoxComm’s behalf and under EACA/VoxComm’s instructions. In addition, EACA/ VoxComm will impose in writing appropriate data protection and information security requirements on such third-party processors.
1.5. Data retention
EACA/VoxComm will retain the Personal Contact Data for the duration of the contract with the respective EACA/VoxComm Member Organisation in accordance with applicable legal requirements, and only for as long as necessary for the purposes described in this Policy or as long as required by law or to defend potential legal claims.
EACA/VoxComm will retain your Personal Contact Data as follows:
• Communications: Personal Data will be kept until you withdraw your consent;
• Event booking: for 1 year after the event, unless you withdraw your consent to the processing of your Personal Data earlier;
• Information, enquiries and services: for 1 year, unless you withdraw your consent to the processing of your Personal Data earlier;
• Photographs/videos: Personal Data will be kept until you validly object to our legitimate interest to process your personal data;
EACA/VoxComm will retain your Personal Contact Data in accordance with applicable legal requirements, and only for as long as necessary for the purposes described in this Policy, as indicated above or as long as required by law or to defend potential legal claims.
SECTION II: Data Processing in connection with our WEBSITE
EACA/VoxComm is the data controller for this Website under the GDPR.
2.2. What Data do we collect about you?
2.2.1. The personal data that we collect directly from you when using our website.
This is the personal data that you voluntarily communicate to us:
(i) through our Website when you contact us via any of the e-mails provided under Team in the tab About Us. We use your data in order to be able to contact you and respond to your requests for information or assistance and to satisfy your requests. The legal basis of the processing is your consent.
(ii) When you contact us for assistance or contact our various services by telephone, you may be asked to provide us with information about yourself, the nature of your call and other information to answer subsequent questions. In this case, your data are used to respond to your requests for information or assistance.
EACA/VoxComm processes your data only to the extent necessary for the purposes for which it was obtained.
2.2.2. The Data we collect when you interact with the Website
Our Webite uses “cookies”. By using the Website, you agree to receive cookies on your computer, tablet or smartphone. It is thanks to cookies that we can offer you optimal navigation on our Site (for example, they help us to remember your preferences since your visit).
Cookies used on our Website perform two functions:
(a) Essential cookies, are essential for the operation of our Website and subpages, including
• Session cookies – they are used to maintain the user session open in the browser and expire when you close your browser.
We recommend you not to disable these cookies, as this may affect your browsing experience.
(b) Performance and analytics cookies (Google Analytics), are used by us to understand how visitors use our Website so we can optimize your browsing experience. More information Google Analytics can be found under “social plug-ins”.
You can prevent cookies from being installed on your browser by changing your browser settings so that cookies from this website cannot be placed on your computer or mobile device.
In certain circumstances, our Website and our applications will provide you with social plug-ins from different social networks. If you choose to interact with a social networking site such as Facebook or Twitter (for example, by registering an account), your activity on our Website or through our applications will also be accessible on that social networking site. If you are connected to one of these social networks during your visit to our Site or if you interact with one of the social plug-ins, the social network site may add this information to your respective profile on that network depending on your privacy settings. If you wish to prevent this type of data transfer, please log out of your social network account before accessing our Site, or change the privacy settings of the application, if possible. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal information, your rights and how you can obtain satisfactory privacy settings.
We monitor non-personal data via Google Analytics. Google Analytics is a web analysis service of Google Ireland Limited that analyses how users interact with the site. On behalf of EACA/VoxComm and based on your consent. Google uses this information to report on website activity, which allows us:
• To analyse how our website is used and assess how its functionality and your browsing experience can be improved
• For example, we monitor the website traffic, the number of page visits per site, the number of downloads of documents on our website, etc.
We use the IP anonymization in order to ensure anonymous collection of IP addresses (so-called IP masking). The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. Personal data will be transferred to the US by Google using Model Contract Clauses. The data is automatically deleted after 14 months.
SECTION III: COMMON PROVISIONS
3.1. Confidentiality and Security
EACA/VoxComm’s employees or any of EACA/VoxComm’s contractual partners who have access to your data in order to provide services to EACA/VoxComm (e.g. its online domain/website hosting supplier, its database software supplier) are contractually obliged to keep such information in confidence and may not use these data for any other purpose than performing their contractual missions for EACA/VoxComm.
We will not disclose, sell, rent or exchange your personal data to any other organization or entity unless you are first notified and you expressly agree to it, or as otherwise required by law e.g. doing what a local or foreign court or government agency requires us to do, disclosing Personal Data to another company if we are or may be selling, assigning, or otherwise transferring all or any part of our business or merging with another company.
We maintain reasonable physical, electronic, standard security practices, including encryption, passwords and physical security measures, and managerial procedures to protect the security and confidentiality of personal data. Only a limited number of persons within us are authorized to access, delete or modify your data. We will make reasonable efforts to ensure that your privacy interests are protected.
EACA/VoxComm stores your data safely and, therefore, EACA/VoxComm maintains appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage to personal data.
Only a limited number of persons within our organisation are authorized to access, delete or modify your data. These measures are aimed at ensuring the on-going integrity and confidentiality of personal data. EACA/VoxComm evaluates these measures on a regular basis to ensure the security of the processing.
3.3. What are your rights?
To the extent required by applicable law and subject to legal limitations, you have the right:
• to have access to your data;
• to have inaccurate data corrected or removed,
• to object to the processing of your data;
• to restrict EACA/VoxComm’s use of your data;
• to the erasure of your data;
• to receive your data in a usable electronic format and transmit it to a third party (right to “data portability”); and
• to lodge a complaint with their local data protection authority
In particular, EACA/VoxComm is committed to working with you to obtain a fair resolution of any complaint or concerns about privacy. If, however, you believe that EACA/VoxComm has not been able to assist with your complaint or concern, you have the right to make a complaint with the competent EU Member State authority.
If you have any questions or wishes in connection with your personal data or you want to exercise your rights, please contact EACA/VoxComm by sending an e-mail to firstname.lastname@example.org
3.4. Transfer outside the EU
The persons and companies to whom we may disclose personal data for any of the above reasons may be located in Belgium or in other countries. These other countries might not have laws that provide the same level of data protection as the GDPR. However, those persons or companies must agree to protect any personal data we give them from improper use and disclosure. We will secure appropriate contractual guarantees from such persons or companies’ service providers to ensure equivalent level of protection to personal data, as required by the GDPR.
3.5. Applicable law and Jurisdiction
3.6. How to Contact Us?
For privacy-related enquiries: email@example.com
For general enquiries: firstname.lastname@example.org
3.7. Notice updates
In case of any material changes to the way in which EACA/VoxComm collects or uses Personal Data, the type of Personal Data it collects or any other aspect of this Policy, EACA/VoxComm will issue a revised Policy.
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