“User”, “you” or “your” refers to the person, company or organization that visits our Website.
3. Who we are
SCE is a limited liability European Cooperative Society, organized under the laws of Luxembourg, registered office at 53 Boulevard Royal, 2449 Luxembourg, R.C.S. Luxembourg, which is the company that controls the collection and processing of any personal data that you provide to us in relation to this Website.
4. What information we collect
Information is gathered from you in a range of ways that are outlined below:
4.1. Information you give us
We collect personal data directly from you as follows:
- When you sign up to receive news services, we may ask you to provide your contact (e.g. e-mail address) as well as your communication preferences;
- when you use our website or one of our online services we collect information about your visit and how you interact with our website;
- when you provide us feedback or contact us via e-mail, we may collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply and with respect to ongoing customer support.
4.2 Information we collect form third parties
Most of the personal data that we collect about you will be information that you provide to us voluntarily. In some circumstances we may also receive information from:
SCE affiliates and/or other group entities;
- regulatory bodies;
- public sources;
- other companies providing services to us.
4.3 Information automatically collected from your use of Website
5. How we use your information
We will only use your personal data fairly and where we have a lawful reason to do so. Our use of your personal data depends on how and where you interact with us.
5.1 Purposes of use and legal basis
We may use the collected information for the following purposes:
Fulfilment of services
To enable us to perform the services to you – to carry out our contractual obligations relating to you, to manage our relationship with you which will also include notifying you about changes to our service and changes to our terms or policies.
Legal basis: It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you.
To enable us to respond to your requests in accordance with the content of your request.
Legal basis: It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.
To provide news and information services including e-mail briefings and newsletters.
Legal basis: We will only send you marketing communications where you have consented and expressed a preference to receive such marketing communications, where it is appropriate and relevant to our business relationship with you, or where we have other lawful right to do so.
User insight and analysis
To collect insights into how you interact with our services so that we can personalise our communications with you and maintain and improve our websites and services.
Legal basis: Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we deliver our Website and online services to you and our other clients effectively. Where lawfully required, we may also process your personal information in accordance with your consent to the processing.
Compliance with legal obligations
To comply with legal and regulatory obligations to which we are a subject.
Legal basis: It is our legal obligation to do so.
5.2 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at: firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5.3 Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time. You can exercise this right by contacting us on: email@example.com, by clicking on the “unsubscribe” button on our marketing e-mails or by choosing a similar opt-out option that we may provide for you to exercise your right to object to the processing of your personal data.
6. How we store and secure your personal data
Where applicable, your personal data is collected and processed in compliance with the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR). We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees and third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Transferring your information outside of the European Economic Area
Your personal data is primarily stored and processed inside EEA,. Your personal data can therefore be subject to privacy laws that are different from those in your country of residence. However, if we do transfer personal data collected within the EU to third parties outside the EU, such transfer will be based on the safeguards either of the standard contractual clauses issued by the EU Commission. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data. By using our website, you consent to your personal data being transferred to other countries. Please contact us for further information about these transfers: firstname.lastname@example.org.
8. Personal data retention
We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.
In some circumstances, certain personal data can be removed on your request. Also, note that due to technical limitations, the data may not be removed instantly. Please contact us for further information: email@example.com
9. To whom we disclose your personal data
For achieving the purposes of use set out in Section 5 above, your data may be accessible to certain categories of persons, employed or contracted by us, that are involved with the operation of our service, including lawyers, administrators, IT and system administration services provider, marketing and other services providers.
We may also share your personal data with law enforcement, data protection authorities, government officials, and other authorities when:
- compelled by subpoena, court order, or other valid legal procedure;
- we believe that the disclosure is necessary to prevent physical harm or financial loss;
- disclosure is necessary to report suspected illegal activity;
- we obtain your consent or at your instruction.
We may also disclose certain personal data to our current or future affiliates, subsidiaries and other related entities, as well as to our operational and business partners and sub-contractors when this is necessary for the performance and execution of any contract we enter into with them or you.
10. Third party links
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
11. What rights you have regarding your personal data
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Request access to your personal data
You have the right to request that we provide you access to your personal data held by us.
Request correction of your personal data
You have the right to request correction of any personal data we hold on you that is inaccurate, incorrect, or out of date.
Request erasure of your personal data
You have the right to request deletion of your data when it is no longer necessary, or no longer subject to legal obligations to which we are subject to. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data
You have the right to request that we cease processing some of your personal data, such as personal data processed for direct marketing purposes. Also, you have the right to object to solely automated processing and to profiling activities based on our own legitimate interests.
Request restriction of processing your personal data
You have the right to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns with this information, or we no longer need your personal data for the purposes of the processing, but they are necessary for the establishment, exercise or defence of legal claims).
Request transfer of your personal data
You have the right to request an export of your personal data.
Right to withdraw consent
Where you have provided your consent to our processing of personal data, you have the right to withdraw it at any time.
Requests are generally free of charge and we try to respond to all legitimate requests within two weeks. However, we may take more time and/or charge a fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may also need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. If you wish to exercise any of the rights set out above, please contact us: firstname.lastname@example.org
The People’s SCE
If you believe that the processing of your data violates data privacy law or that your data privacy rights have been violated in some other way, you can also lodge a complaint with your local data protection authority.
We would, however, appreciate the opportunity to deal with your concerns before you approach the authorities, so please contact us in the first instance.
©The People’s SCE (October 2021)