Privacy policy
1. Introduction
1.1 We are committed to safeguarding the privacy of PHAP members, subscribers, website visitors, and service users.
1.2 This policy applies where we are acting as a data controller
with respect to the personal data of PHAP members, subscribers, website
visitors, and service users; in other words, where we determine the
purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are
not strictly necessary for the provision of our website and services, we
will ask you to consent to our use of cookies when you first visit our
website.
1.4 Our website incorporates privacy controls which affect how we
will process your personal data. By using the privacy controls, you can
specify whether you would like to receive direct marketing
communications and limit the publication of your information. You can
access the privacy controls via the link at the bottom of marketing
communications emails. If you are a PHAP member, you can also access the
privacy controls via your user account after logging in.
1.5 In this policy, "we", "us" and "our" refer to the International Association of Professionals in Humanitarian Assistance and Protection (PHAP) aisbl. For more information about us, see Section 12.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data").
The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of
visit, page views, and website navigation paths, as well as information
about the timing, frequency and pattern of your service use. The source
of the usage data is Google Analytics and our iMIS analytics tracking
system. This usage data may be processed for the purposes of analyzing
the use of the website and services. The legal basis for this processing
is our legitimate interests, namely monitoring and improving our
website and services.
2.3 We may process your account data ("account data").
The account data may include your name and email address. The source of
the account data is you. The account data may be processed for the
purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our
databases, and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration
of our website and business.
2.4 We may process your information included in your personal profile on our website ("profile data").
The profile data may include your name, address, telephone number,
email address, profile pictures, gender, date of birth, citizenship,
relationship status, language skills, interests and hobbies, educational
details, and employment details. The profile data may be processed for
the purposes of enabling and monitoring your use of our website and
services. The legal basis for this processing is consent.
2.5 We may process your personal data that are provided in the course of the use of our services ("service data").
The service data may include time of use, duration of use, frequency of
use, and location of use. The service data may be processed for the
purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our
databases, and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration
of our website and business.
2.6 We may process information that you post for publication on our website or through our services ("publication data").
The publication data may be processed for the purposes of enabling such
publication and administering our website and services. The legal basis
for this processing is consent.
2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data").
The enquiry data may be processed for the purposes of offering,
marketing, and selling relevant goods and/or services to you. The legal
basis for this processing is consent.
2.8 We may process information relating to our member, subscriber,
partner, or customer relationships, including member, partner, or
customer contact information ("customer relationship data").
The customer relationship data may include your name, your employer,
your job title or role, your contact details, your membership details,
and information contained in communications between us and you or your
employer. The customer relationship data may be processed for the
purposes of managing our relationships and communicating with members,
subscribers, partners, and customers and keeping records of those
communications and promoting our products and services. The legal basis
for this processing is our legitimate interests, namely the proper
management of our customer relationships.
2.9 We may process information relating to transactions, including
registrations for free products and services as well as purchases of
goods and services, that you enter into with us and/or through our
website ("transaction data"). The transaction data may
include your contact details, your bank or credit card details, and the
transaction details. The transaction data may be processed for the
purpose of supplying the purchased goods and services and keeping proper
records of those transactions. We offer the use of a secure server. All
supplied sensitive/credit information is transmitted via Secure Socket
Layer (SSL) technology and then encrypted into our Payment gateway
providers database only to be accessible by those authorized with
special access rights to such systems, and are required to keep the
information confidential. After a transaction, your credit card details
will not be stored on our servers. The legal basis for this processing
is the performance of a contract between you and us and/or taking steps,
at your request, to enter into such a contract and our legitimate
interests, namely the proper administration of our website and business.
2.10 We may process information that you provide to us for the
purpose of subscribing to our email notifications and/or newsletters ("notification data").
The notification data may be processed for the purposes of sending you
the relevant notifications and/or newsletters. The legal basis for this
processing is consent or the performance of a contract between you and
us and/or taking steps, at your request, to enter into such a contract.
2.11 We may process information contained in or relating to any communication that you send to us ("correspondence data").
The correspondence data may include the communication content and
metadata associated with the communication. Our website will generate
the metadata associated with communications made using the website
contact forms. The correspondence data may be processed for the purposes
of communicating with you and record-keeping. The legal basis for this
processing is our legitimate interests, namely the proper administration
of our website and business and communications with users.
2.12 We may process event registration data (“event registration data”).
This data may include your name, email address, address, phone number,
birth date, employer, job title or role, country based in, language
skills, and event preferences. The source of this data is you or your
employer. This data may be processed for the purposes of providing you
with relevant event services, sending you communications about events
you have registered for, keeping records of those registrations, and
customizing notifications and/or newsletters for which you have provided
your consent. The legal basis for this processing is the performance of
a contract between you and us and/or taking steps, at your request, to
enter into such a contract.
2.13 We may process information regarding your membership in PHAP (“membership data”).
This data may include your name, email address, address, phone number,
birth date, citizenship, and membership details. This data may be
processed for the purposes of maintaining a database of members,
communicating to you about your membership and its maintenance, and
communicating to you about the governance of the association. The legal
basis for this processing is the performance of a contract between you
and us and/or taking steps, at your request, to enter into such a
contract.
2.13 We may process information regarding to certifications you have earned (“certification data”).
This data may include your name, email address, address, phone number,
birth date, and certification details. This data may be processed for
the purposes of maintaining a database of certification holders and
communicating to you about your certification and its maintenance. The
legal basis for this processing is our legitimate interests, namely the
proper management of a professional certification program following the
requirements of ISO/IEC 17024:2012 Conformity assessment - General requirements for bodies operating certification of persons.
2.14 We may process any of your personal data identified in this
policy where necessary for the establishment, exercise, or defense of
legal claims, whether in court proceedings or in an administrative or
out-of-court procedure. The legal basis for this processing is our
legitimate interests, namely the protection and assertion of our legal
rights, your legal rights, and the legal rights of others.
2.15 We may process any of your personal data identified in this
policy where necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, or obtaining professional advice.
The legal basis for this processing is our legitimate interests, namely
the proper protection of our business against risks.
2.16 In addition to the specific purposes for which we may process
your personal data set out in this Section 2, we may also process any of
your personal data where such processing is necessary for compliance
with a legal obligation to which we are subject, or in order to protect
your vital interests or the vital interests of another natural person.
2.17 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or
professional advisers insofar as reasonably necessary for the purposes
of obtaining or maintaining insurance coverage, managing risks,
obtaining professional advice, or the establishment, exercise or defense
of legal claims, whether in court proceedings or in an administrative
or out-of-court procedure.
3.2 We may disclose event registration data to our suppliers or
subcontractors insofar as reasonably necessary for the proper
organization and management of events.
3.3 We may disclose certification data to our suppliers or
subcontractors and in response to inquiries from individuals or
organizations as to whether an individual holds a certification insofar
as reasonably necessary for the proper organization and management of a
professional certification program following the requirements of ISO/IEC 17024:2012 Conformity assessment - General requirements for bodies operating certification of persons.
3.4 We may disclose basic membership data in response to inquiries
from individuals or organizations as to whether an individual is a
member of the association or holds a certification insofar as reasonably
necessary for the organization and management of a professional
membership program and to provide member services dependent on
membership status (such as discounts).
3.5 Financial transactions relating to our website and services
may be handled by our payment services providers, PayPal, Authorize.net,
and iATS. We will share transaction data with our payment services
providers only to the extent necessary for the purposes of processing
your payments, refunding such payments and dealing with complaints and
queries relating to such payments and refunds. You can find information
about the payment services providers' privacy policies and practices at:
(a) https://www.paypal.com/ch/webapps/mpp/ua/privacy-full (PayPal)
(b) https://www.authorize.net/company/privacy/ (Authorize.net)
(c) http://home.iatspayments.com/privacy-policy/ (iATS)
3.6 We may disclose your enquiry data to one or more of those
selected third party suppliers of goods and services to which you have
agreed to be contacted by for the purpose of enabling them to contact
you so that they can offer, market and sell to you relevant goods and/or
services. Each such third party will act as a data controller in
relation to the enquiry data that we supply to it; and upon contacting
you, each such third party will supply to you a copy of its own privacy
policy, which will govern that third party's use of your personal data.
3.7 In addition to the specific disclosures of personal data set
out in this Section 3, we may disclose your personal data where such
disclosure is necessary for compliance with a legal obligation to which
we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal
data where such disclosure is necessary for the establishment,
exercise, or defense of legal claims, whether in court proceedings or in
an administrative or out-of-court procedure.
3.8 Occasionally, at our discretion, we may include or offer third
party products or services on our website. These third party sites have
separate and independent privacy policies. We therefore have no
responsibility or liability for the content and activities of these
linked sites. Nonetheless, we seek to protect the integrity of our site
and welcome any feedback about these sites.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the
circumstances in which your personal data may be transferred to
countries outside the European Economic Area (EEA).
4.2 Our community management platform is situated in the United
States. The European Commission has made an "adequacy decision" with
respect to the data protection laws of the United States under the
Privacy Shield Framework. Transfers to the United States will be
protected by appropriate safeguards, namely the use of standard data
protection clauses of the EU-U.S. Privacy Shield Principles and
Swiss-E.U. Privacy Shield Framework, a copy of which can be obtained
from https://www.privacyshield.gov/EU-US-Framework.
4.3 You acknowledge that personal data that you submit for
publication through our website or services may be available, via the
internet, around the world. We cannot prevent the use (or misuse) of
such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and
procedure, which are designed to help ensure that we comply with our
legal obligations in relation to the retention and deletion of personal
data.
5.2 We will hold your personal information on our systems for as
long as is necessary for the relevant activity or as long as is set out
in any relevant agreement you enter into with PHAP (including, but not
limited to, any Terms and Conditions of Use for a website).
5.3 You may request the deletion of your personal information from our systems by sending an email to [email protected] specifying your name and email address(es).
5.4 Notwithstanding the other provisions of this Section 5, we may
retain your personal data where such retention is necessary for
compliance with a legal obligation to which we are subject, or in order
to protect your vital interests or the vital interests of another
natural person.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
7. Your rights
7.1 In this Section 7, we have summarized the rights that you have
under data protection law in the European Union. Some of the rights are
complex, and not all of the details have been included in our
summaries. Your specific rights will differ depending on your country of
residence and/or citizenship. Accordingly, you should read the relevant
laws and guidance from the regulatory authorities for a full
explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we
process your personal data and, where we do, access to the personal
data, together with certain additional information. That additional
information includes details of the purposes of the processing, the
categories of personal data concerned and the recipients of the personal
data. Providing the rights and freedoms of others are not affected, we
will supply to you a copy of your personal data. The first copy will be
provided free of charge, but additional copies may be subject to a
reasonable fee.
7.4 You have the right to have any inaccurate personal data about
you rectified and, taking into account the purposes of the processing,
to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of
your personal data without undue delay. Those circumstances include: the
personal data are no longer necessary in relation to the purposes for
which they were collected or otherwise processed; you withdraw consent
to consent-based processing; you object to the processing under certain
rules of applicable data protection law; the processing is for direct
marketing purposes; and the personal data have been unlawfully
processed. However, there are exclusions of the right to erasure. The
general exclusions include where processing is necessary: for exercising
the right of freedom of expression and information; for compliance with
a legal obligation; or for the establishment, exercise or defense of
legal claims.
7.6 In some circumstances you have the right to restrict the
processing of your personal data. Those circumstances are: you contest
the accuracy of the personal data; processing is unlawful but you oppose
erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment,
exercise or defense of legal claims; and you have objected to
processing, pending the verification of that objection. Where processing
has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your
consent; for the establishment, exercise or defense of legal claims; for
the protection of the rights of another natural or legal person; or for
reasons of important public interest.
7.7 You have the right to object to our processing of your
personal data on grounds relating to your particular situation, but only
to the extent that the legal basis for the processing is that the
processing is necessary for: the performance of a task carried out in
the public interest or in the exercise of any official authority vested
in us; or the purposes of the legitimate interests pursued by us or by a
third party. If you make such an objection, we will cease to process
the personal information unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or
defense of legal claims.
7.8 You have the right to object to our processing of your
personal data for direct marketing purposes (including profiling for
direct marketing purposes). If you make such an objection, we will cease
to process your personal data for this purpose.
7.9 You have the right to object to our processing of your
personal data for scientific or historical research purposes or
statistical purposes on grounds relating to your particular situation,
unless the processing is necessary for the performance of a task carried
out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a
contract to which you are party or in order to take steps at your
request prior to entering into a contract,
and such processing is carried out by automated means, you have the
right to receive your personal data from us in a structured, commonly
used and machine-readable format. However, this right does not apply
where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal
information infringes data protection laws, you have a legal right to
lodge a complaint with a supervisory authority responsible for data
protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your
personal information is consent, you have the right to withdraw that
consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your
personal data by written notice to us, in addition to the other methods
specified in this Section 7.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of
letters and numbers) that is sent by a web server to a web browser and
is stored by the browser. The identifier is then sent back to the server
each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session"
cookies: a persistent cookie will be stored by a web browser and will
remain valid until its set expiry date, unless deleted by the user
before the expiry date; a session cookie, on the other hand, will expire
at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that
personally identifies a user, but personal information that we store
about you may be linked to the information stored in and obtained from
cookies.
9. Cookies that we use
9.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are logged into our website;
(c) personalization - we use cookies to store information about your preferences and to personalize the website for you;
(d) security - we use cookies as an element of the security
measures used to protect user accounts, including preventing fraudulent
use of login credentials, and to protect our website and services
generally;
(e) advertising - we use cookies to help us to display advertisements that will be relevant to you;
(f) analysis - we use cookies to help us to analyze the use and performance of our website and services; and
(g) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
10. Cookies used by our service providers
10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
10.2 We use Google Analytics to analyze the use of our website.
Google Analytics gathers information about website use by means of
cookies. The information gathered relating to our website is used to
create reports about the use of our website. Google's privacy policy is
available at: https://www.google.com/policies/privacy/.
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to
delete cookies. The methods for doing so vary from browser to browser,
and from version to version. You can however obtain up-to-date
information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-ph/guide/safari/sfri11471/mac (Safari);
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Other data privacy policies
12.1 We have taken the necessary precautions to be in compliance
with the California Online Privacy Protection Act. We therefore will not
distribute your personal information to outside parties without your
consent. As part of the California Online Privacy Protection Act, all
users of our site may make any changes to their information at anytime
by logging into their control panel and going to the "My Profile" page.
12.2 We are in compliance with the requirements of COPPA (Childrens
Online Privacy Protection Act), we do not collect any information from
anyone under 13 years of age. Our website, products and services are all
directed to people who are at least 13 years old or older.
13. Our details
13.1 This website is owned and operated by the International Association of Professionals in Humanitarian Assistance and Protection (PHAP) aisbl.
13.2 We are registered in Belgium under registration number 0827.806.710, and our registered office is at Avenue de la Chasse 133-135, 1040 Brussels, Belgium.
13.3 Our principal place of business is at Avenue de la Chasse 133-135, 1040 Brussels, Belgium.
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.