Last update: 12th April 2021
Table of content
CISPE understands that privacy is important and that users care about how your personal data is used. We respect and value the privacy of everyone who visits our website and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
“Data Protection Law” means the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) and implementing national laws, in particular the Belgian Data Protection Act of Act of 30 July 2018.
Our Site is owned and operated by Cloud Infrastructure Services Providers in Europe ASBL, which is a not-for-profit association registered in Belgium and the controller of your personal data collected on this Site.
Address: Avenue Louise 87, 1050 Bruxelles, Belgium,
RPM: 0666.662.093 RPM Brussels
Email address: firstname.lastname@example.org
Telephone number: +32 2 513 06 55
Personal data is defined by the GDPR as ‘any information relating to an identified or identifiable natural person’, i.e. who can be identified, directly or indirectly, in particular by reference to an identifier.
Personal data is, in simpler terms, any information about you that enables you to be identified directly or indirectly. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Below you can find out how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details below to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details below to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- Right to object to direct marketing
When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such direct marketing purposes (including profiling insofar as it relates to such direct marketing).
- The right to data portability. This means that, if you have provided personal data to us, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us to provide you that personal data in a structured, commonly used and machine-readable format, and to transmit such personal data directly to another controller where technically feasible.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
Further information about your rights can also be obtained from the Belgium Data Protection Authority (www.dataprotectionauthority.be).
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Belgium Data Protection Authority.
Depending upon your use of our Site, we may collect some or all of the following personal data about you:
- “Get Involved” : We collect your name, email address, organization, job title and other details you provide when signing-up to find out more about the Principles of Fair Software Licensing, to join our campaign or to share information on how your business has been affected by unfair software licensing or other feedback in that respect.
- Activities and events: We may collect your name, email address, business address, job title and phone number when your register to activities, programs and events and to organise such activities, programs and events.
- Contact us: You may provide us with your name, organization and email address when you communicate with us via the Site.
In certain sections of this Site you are asked to provide your personal data, in particular your identification details (name and surname and organisation), contact details (emails), and other information such as feedback as to how you or your business has been affected by unfair software licensing, and to confirm how we can use such personal data. When we ask you to provide your personal data on certain sections of the Site (“Get Involved”, “Contact us”), please note that certain fields will be marked as mandatory. These are data we need to be able to involve you in the campaign or provide you with other services or information you requested. If you choose not to provide us with these data, we may not be able to involve you in the campaign or provide you with the requested service or information.
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you (Article 6.1.b GDPR), because you have consented to our use of your personal data (Article 6.1.a GDPR), because we have a legal obligation to process your data (Article 6.1.c GDPR) or because it is in our legitimate business interests to use it, without that our interests be overridden by your own interests and fundamental rights and freedoms (Article 6.1.f GDPR). Your personal data will be used for the following purposes based on the following legal bases:
Purposes of processing
We may use and record your personal data to allow you to join and support the campaign on the Principles of Fair Software Licensing and communicating with you in that respect, including, if you have agreed by ticking the relevant boxes on the Site:
– to advertise (share publicly / publish on this Site), in particular on our ‘Supporters page’, your support to the Principles of Fair Software Licensing ;
– to share publicly / publish on this Site, in particular on our ‘Supporters page’ – in an anonymous or pseudonymous way, i.e. without citing your name or organization – the experience or feedback you have shared with us in relation to unfair software licensing;
– to get in touch to discuss the content of the experience and message you shared with us on our Site;
– to send you further information (by email) about the Principle of Fair Software Licensing or our other initiatives.
Your personal data will be processed based on:
– your consent that you provide when ticking appropriate tick boxes on the Site, or
– our legitimate interests to operate the campaign on the Principles of Fair Software Licensing.
We may use your personal data to manage our relationship and/or to answer your specific questions, feedback or claims regarding our Site or the Principles of Fair Software Licensing.
Your personal data will be processed based on:
· the necessity of the processing for the performance of a contract with you or in order to take steps at your request prior to entering into a contract, or
· our legitimate interests to manage and maintain our relationship, and provide you the answers, feedback and support you need.
We may use your personal data to fulfil other legitimate purposes disclosed to you at the time you provide your personal data or as permitted or required to comply with applicable laws and regulations to which we are subject.
Your personal data will be processed because the processing is necessary:
We shall obtain your prior express consent (opt-in) for the above-listed purposes where required under applicable law. You have the right to withdraw any given consent at any time (see Section What are your rights? above).
We may disclose your personal data in the following circumstances, to the extent reasonably necessary or desirable for us to disclose your personal data in order to carry out the above-mentioned purposes in accordance with applicable law:
- We may share your Personal Data with third party service providers who provide services on our behalf and under our instructions. These third parties which are communications consultants based in Brussels may have access to or process your Personal Data as part of providing services to us.
- Information regarding your support to the Principles of Fair Software Licensing and the feedback and experience you share with us in relation to unfair software licensing may be disclosed on our Site, as well as to media and policy audiences without personal identifiable information in the context of CISPE’s activities and events (e.g., during a conference or a meeting). However, express additional permission will be sought before any personal identifiable information is shared.
- If you consent to our disclosure of information to a third party, such as on our Site or to business partners, or as otherwise authorised under applicable law.
- We may preserve and disclose your personal data if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or request, or to otherwise cooperate with law enforcement or other governmental agencies.
- We also reserve the right to preserve and disclose your personal data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Site and any facilities or equipment used to make the Site available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
- Your Personal Data may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which personal data is transferred to one or more third parties as one of our business assets.
In addition, we may collect, use and share anonymous data such as statistical information about the use of the Site.
The Site contains links to third-party websites which are not managed by CISPE. Any Personal Data you provide on third-party websites is subject to those third-parties’ privacy policies. We are not responsible for the practices and policies of such third-party websites. We invite you to carefully review these third-party websites’ privacy policies before submitting any personal data to them.
We use organisational and technical security measures that are designed to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, or any other unlawful form of processing.
However, please note that no electronic transmission or storage of information is 100% secure. Therefore, despite all security measures that we have put in place to protect your personal data, we cannot guarantee that loss, misuse, or alteration of data will never occur and therefore invite you to be prudent when disclosing your personal data online.
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU Member States, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
In addition to your rights under the GDPR, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
You may access our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain personal data. Providing us with your personal data (when marked with an asterisk) is a contractual requirement, and we may not be able to involve you in our campaign or provide you with the requested service or information if you do not provide us with such personal data.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing, signed and sent to the email or addresses provided in contact details with evidence of your identity.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within as soon as possible and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time, provided that this does not affect the rights and freedoms of others. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Our Site does not place any Cookies on your computer or device.
To contact us about anything to do with your personal data and data protection, including to make a subject access request or to exercise any of your rights above, please use the following contact details:
Email address: email@example.com
Telephone number: +32 2 513 06 55
Address: Avenue Louise 87, 1050 Bruxelles, Belgium