Data controller – Who are we?
European Network of Political Foundations (ENoP)
Address: 42 Rue de l’Industrie, BE-1040 Brussels, Belgium
Telephone number: +32 (0) 22 30 00 29
E-mail address: email@example.com
1. General data
The European Network of Political Foundations (“ENoP”, “we”) is committed to respecting the privacy of visitors to its website and individuals who register to attend ENoP’s events or subscribe to ENoP’s newsletter.
2. Collection and processing of personal data
When you register as an ENoP member on our website, you are asked to provide your name, organisation and e-mail address. You are also asked to choose your username and password. We need this data to verify your membership status and to create your user account. You can manage your profile and settings via your account profile.
When you sign up to ENoP’s newsletter you are asked to provide your e-mail address. This is necessary to send you the latest news from the ENoP network.
Based on your newsletter subscription (external/member), we may collect additional data in order to understand our audience better and tailor the content based on their preferences:
External newsletter: organisation, position, country
Member newsletter: organisation, position, country, involvement in ENoP bodies, content preferences
We use the MailChimp marketing platform to send out our newsletter and analyse its performance. Learn more about MailChimp’s privacy practises here.
You can unsubscribe from our newsletter at any point without having to give a reason why. Every newsletter contains a reminder of the possibility to unsubscribe and a link to do it easily and quickly. When you unsubscribe, your personal data is then automatically deleted from the register. If you change your mind, you will have to sign up for a newsletter again.
If you register on our website for an event organised by ENoP, we collect personal data related to your professional status (name, e-mail address, organisation and position). This data is required for you to be able to attend the event.
When applying for a position with ENoP, we collect personal data included in your résumé, C.V., employment history, education history, references and any other data you may submit to ENoP in the process. This data is required in order to assess your eligibility for the role.
If you accept analytical cookies before using our website, your personal data is shared with a third-party company based outside the EU called Google Analytics (owned by Google LLC and operated by Google Ireland Limited for EMEA), whose software we use to track and analyse how people use and interact with our website.
We use the IP Anonymization feature of Google Analytics, which will strip the last part from the user’s IP address within Europe before the user’s data is passed along to Google LLC in the US. Learn more about how Google manages data here and you can view Google’s currently available opt-out options here.
We also store the names, positions and e-mail addresses of our partners external to our organisation. These include other democracy support organisations, NGO networks, universities, think tanks and EU officials. Data processing is limited to direct exchanges with these external contacts, like requests for meetings, invitations to events, sharing publications, requests for cooperating on programmes, etc.
Embedded content from other websites
Necessary (functional) cookies – necessary cookies are essential and help you navigate the Website. For this reason, they do not require your consent. They enhance the user friendliness of the Website for visitors. These cookies help to support Website security and basic functionality.
Analytics cookies – analytics cookies help us to understand the behavior of our visitors and the usage of the Website in an aggregated manner. For instance, we can use these cookies to gain insight into how our visitors use our website. This means we can find out what works and what doesn’t, it allows us to continuously improve the Website, and measure how effective our communication and user interaction is.
Managing Cookie Preferences
You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Be aware though that you may also lose some saved data (e.g. saved login details, site preferences).
4. With whom we share your data with
ENoP does not share, sell, rent, or trade any personal data with third parties for their promotional purposes. ENoP may share data with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, trainings, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
We may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to: comply with the law and the reasonable requests of law enforcement; detect and investigate illegal activities and breaches of agreements; and/or exercise or protect the rights, property, or personal safety of ENoP, its members or others.
International transfer of personal data
In general ENoP does not transfer any personal data out of the European Economic Area (“EEA”). We store data in the European Union and our servers are based in Frankfurt, Germany.
Sometimes a minimal set of personal data of our members or event attendees (name, organisation and function) may be transferred to our partners outside the EEA. You will be informed before every such transfer takes place. In that case ENoP implements appropriate safeguards for transfers of personal data, including Standard Contractual Clauses approved by the EU Commission or similar contractual clauses in other jurisdictions.
The security of your personal data is very important to ENoP. That’s why we use physical, electronic, and administrative safeguards that are designed to protect your data from loss, misuse, and unauthorised access, disclosure, alteration, and/or destruction. All personal data we collect will be stored by our hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card data, national identification numbers or other sensitive data that could be used for fraud.
If your Personal data is acquired or is reasonably believed to have been obtained, by an unauthorised person and applicable law requires notification, ENoP will notify you by e-mail or mail.
6. Data subject rights – your rights
Depending on the processing and the legal basis for it, you may request to review, correct, delete, or otherwise modify any of the personal data that you have previously provided to us through our website. In your request, please make clear what personal data you would like to have changed, updated or deleted.
To update your preferences, ask us to remove your data from our mailing lists or submit a request, please contact us via email at firstname.lastname@example.org.
While most questions and issues related to data subject rights can be handled quickly, complex requests may take more research and time than usual. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within 30 days.
Sometimes we may require additional data to verify your identity before responding to your request to minimise the risk of abuse of the rights and fraudulent requests. ENoP will never ask for a copy of ID or other identification document during the verification process.
We will review each individual request, and should we conclude that the rights invoked do not apply, we will also give our reasons for such an assessment in writing.
You have the following rights in respect of your personal data that we process:
Right of access
You have the right to obtain confirmation of whether, and where, we are processing your personal data; data about the categories of personal data we are processing, the purposes for which we process your personal data and data as to how we determine applicable retention periods; data about the categories of recipients with whom we may share your personal data; and a copy of the personal data we hold about you.
Right to rectification
You have the right to obtain rectification of any inaccurate or incomplete personal data we process about you without undue delay.
Right to erasure
You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
Right to restriction of processing
You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Right of data portability
You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
Right to object
You have the right object to any processing based on our legitimate interests where there are grounds relating to your situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
Right to withdraw consent
If you have provided consent for processing of your personal data (e.g. newsletter), you have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
Finally, you have the right to issue a formal complaint with the relevant national data protection authority. You can always contact Belgian Data Protection Authority (GBA) – https://www.dataprotectionauthority.be/
Address: Rue de la Presse 35, 1000 Brussels
Telephone number: +32 (0)2 274 48 00
7. Retention and deletion
The criteria used to determine the period for which personal data about you will be retained varies depending on the purposes or legal basis under which we process the personal data. In addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorised use or disclosure of your personal data.
At the end of the retention period, ENoP will delete your personal data in a manner designed to ensure that it cannot be reconstructed or read.
Consent: Where we are processing personal data based on your consent, we generally will retain the data until you withdraw your consent.
Contract: Where we are processing personal data based on contract, we generally will retain the data for the duration of the contract plus some additional limited period (usually 10 years) that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Legal obligation: Where we are processing personal data based on a legal obligation, we generally will retain the data for the period necessary to fulfill the legal obligation. That period is usually prescribed by law, and it may vary depending on the nature of legal obligation.
Legitimate interests: Where we are processing personal data based on our legitimate interests, we generally will retain such data for a reasonable period based on the particular interest, considering the fundamental interests and the rights and freedoms of data subjects. For each specific processing data subjects will be provided with a period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period.
Legal claim: We may need to apply a “legal hold” of personal data that retains data beyond our typical retention period where we face threat of legal claim. In that case, we will retain the data until the hold is removed, which typically means the claim or threat of claim has been resolved.