1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors, service users and any other third party individual we may need to collect information on within the context of our business activities (including key stakeholders within a given field such as politicians, experts, etc.).

1.2    This notice explains how we use personal data relating to these individuals, where we are acting as a data controller with respect to such personal data; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, “we”, “us” and “our” refer to FIPRA International Limited.

2. How we use your personal data

2.1     In this Section 2 we have set out:

(a) the categories of personal data that we may collect or process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

2.2    Personal data that you have provided to us

2.2.1   We may process the personal data we obtain directly from you, either when you visit our website or when you otherwise use our services, as shown in the table below:

Why we process your personal dataPersonal data we collect about youLegal ground for processing
For the provision of our services and to manage our contractual relationship with our clientsPersonal data provided in the course of the use of our services, including:
– Identification data (name, surname)
– Contact details (email address; phone number)
– professional information (such as your employer, your job title)
– information that you post for publication on our website or through our services (“publication data”)
– information contained in or relating to any communication that you send to us (“correspondence data“), including the communication content and metadata associated with the communication.
Contractual necessity
For client relationship management (including for the organisation of conferences, webinars and other events) and the improvement of our services– Identification data (name, surname)
– Contact details (email address; phone number)
– professional information (such as your employer, your job title, career history)
– correspondence data.
Our legitimate interests to develop and improve our business activities
For the management of our service providers– Identification data (name, surname)
– Contact details (email address; phone number)
– professional information (such as your employer, your job title, career history)
– correspondence data.
Contractual necessity
To answer an enquiry you have submitted to us regarding our servicesInformation contained in any enquiry you submit to us regarding our services (including your name, surname, email address and content of your enquiry).Pre-contractual measures
To answer any other query you may have submitted to usInformation contained in your query, including your name, surname, email address and the content of your query.Your consent
To ensure the security of our website and services and maintain back-ups of our databasesPersonal data provided in the course of the use of our services, including:
– identification data (name, surname)
– contact details (email address, phone number)
– professional information (such as your employer, your job title, career history)
– publication data
– correspondence data.
Our legitimate interests to secure our services and databases
To send you our email notifications and/or newsletters (including commentaries or analysis of political and policy developments, invitations to conferences, webinars or events that we organise)Your name, surname, e-mail address.  In accordance with the applicable rules on electronic marketing communications, we will rely on: Your consent (Opt-in), orOur legitimate interests to promote our services provided that you have not opted-out of our email notifications/newsletter.
For record-keeping purposes and managing any potential litigation claimsPersonal data provided in the course of the use of our services, including:
– Identification data such as name and surname
– Contact details such as email address
– publication data
– correspondence data.
Our legitimate interests to protect our business

2.2.2 In addition, where you have consented to the use of analytics cookies, we may collect and 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. Based on your consent, we may process the usage data for the following purposes:

– Analysing of service usage, enabling us to offer tailored content to users

2.3     Personal data we have not obtained directly from you

2.3.1  In the context of our business activities, we may process personal data about individuals who have not directly shared their information with us. We will only process this personal data as necessary to provide and improve our services to our clients. To this end, we may collect the following categories of information:

– identification data (name, surname) and contact details (usually email address, possibly phone number);

– information regarding the individual’s public position regarding a specific subject.

We obtain this information from publicly available sources (such as public websites). We will process such information on the basis of our legitimate interests to conduct our business activities.

2.3.2 As a general rule, FIPRA does not intentionally collect any personal data revealing an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, nor any genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation (“sensitive personal data”). If, by way of exception, FIPRA does collect some sensitive personal data about an individual and processes such data in the context of its business activities, then it would be on the basis that such data was made manifestly public by the concerned individual (for instance, because such data was readily available on the internet).

2.4     Please do not supply any other person’s personal data to us, unless we prompt you to do so, and you can ensure you have the necessary rights from that person.

2.5     Please note we may also need to process your personal data if required to do so in order to comply with statutory legal obligations with the public authorities, where applicable.

3. Providing your personal data to others

3.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) and to our third-party service providers insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2    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.

3.3    Lastly, we may also share your personal data with other recipients when you have consented to it.

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    We and our other group companies have offices and facilities in Belgium and the UK.

4.3     The hosting facilities for our website are situated in the European Union.

4.4    However, some of our third-party suppliers and partners are located and operate around the world.  This means that when we collect your personal data we may process it in any of these countries.  We have however taken appropriate safeguards to require that your personal data will remain protected in accordance with this privacy policy.

5. Retaining and deleting personal data

5.1    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.2     Notwithstanding the above, 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.

5.3    When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

6. Your data protection rights

6.1    You may instruct us to provide you with relevant information regarding the way we process your personal data, as well as to provide you with a copy of any personal information we hold about you. Kindly note that in this context, we may sometimes have to withhold some information that is requested to the extent permitted by law.

6.2     You may instruct us to correct or update your personal data.

6.3    You may instruct us at any time not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

6.4    In addition, in certain circumstances, as stipulated in the applicable data protection legislation, you can object to processing of your personal data, ask us to restrict the processing of your personal data or request portability of your personal data.

6.5    If we have collected and process your personal data with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

6.6     If you have a complaint or concern about how we are processing your personal data then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your personal data.  For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union and European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here. 6.7      You can exercise all of your data protection rights by contacting us using the contact details provided in the “Contact Us” section below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

6.7      You can exercise all of your data protection rights by contacting us using the contact details provided in the “Contact Us” section below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

7. About Cookies

7.1    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.

7.2    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.

7.3    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.

8. Cookies that we and our service providers use

8.1    We use cookies for the following purposes:

(a)    necessary – we use cookies to ensure the correct functioning of our website in order to personalise the website for you. We also use these cookies to ensure website security is not compromised. Cookies used for this purpose are:

Cookie providerCookie namePurposeDuration
FIPRAPHPSESSIDThis cookie is generated by applications based on the PHP language. This is a general purpose identifier used to maintain user session variables. It is normally a random generated number, how it is used can be specific to the site, but a good example is maintaining a logged-in status for a user between pages. Session cookie
GoogleSID      This cookie is generated by applications based on the PHP language. This is a general purpose identifier used to maintain user session variables. It is normally a random generated number, how it is used can be specific to the site, but a good example is maintaining a logged-in status for a user between pages.5 months

Kindly note that because these necessary cookies are essential to the functioning of our website, you cannot refuse them; they can however be blocked or deleted as described in the section “Managing cookies” below.

(b)    performance and analytics – we use cookies to help us to analyse the use and performance of our website and services. Cookies used for this purpose are:

Cookie providerCookie namePurposeDuration
FIPRA_gatThis performance cookie is used to throttle the request rate – limiting the collection of data on high traffic sites.10 Minutes
FIPRA_gidThis performance cookie is used to store and update a unique value for each page visited. 1 day
FIPRAcookie_notice_acceptedThis cookie is used to check whether or not the end user has accepted the cookie policy or not.1 month
FIPRA_gaThis cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.24 Months

We will only place these “performance and analytics” cookies if you expressly accept them when you first visit our website via our cookie preference banner. Please note you can withdraw your consent for this type of cookie at any time by pressing the relevant button here:  Revoke cookies

To refuse these cookies, you can alternatively also follow the instructions below under the heading “Managing cookies”.

(c)   targeting and advertising – cookies may also be used to make advertising messages more relevant to you.  Cookies used for this purpose are:

Cookie providerCookie namePurposeDuration
DoubleClickIDEThis cookie is used for purposes of real time bidding advertising exchange.6 Months
GoogleHSIDThis cookie is used to build a profile of the website visitor’s interests and show relevant ads on other sites. 5 Months
GoogleAPISIDThis cookie is used to build a profile of the website visitor’s interests and show relevant ads on other sites. This cookie works by uniquely identifying your browser and device.5 Months
GoogleSAPISIDThis cookie is used to build a profile of the website visitor’s interests and show relevant ads on other sites. This cookie works by uniquely identifying your browser and device. 5 Months
GoogleSSIDThis cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website. 5 Months
GoogleNIDThis cookie is used to profile the interests of web users and sell advertising space to organisations based on such interest profiles as well as aligning adverts to the content on the pages where its customer’s adverts appear.6 Months
GoogleCONSENTThis cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website. 210 Months
GstaticCONSENTThis cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website. 210 Months

We will only place these “targeting and advertising” cookies if you expressly accept them when you first visit our website via our cookie preference banner. Please note you can withdraw your consent for this type of cookie at any time by pressing the relevant button here: Revoke cookies

To refuse these cookies, you can also follow the instructions below under the heading “Managing cookies”.

8.2     Our service providers use cookies and those cookies may be stored on your computer when you visit our website. In particular, we use Google Analytics to analyse 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/

9. Managing Cookies

9.1     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/kb/PH21411 (Safari); and adpfm reviews

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

9.2     Blocking all cookies (especially the necessary cookies) may have a negative impact upon the usability of many websites. If you block some cookies, you may not be able to use all the features on our website.

10. Amendments

10.1    We may update this policy from time to time by publishing a new version on our website. You can see when this policy was last updated by checking the “last updated” date at the top of this policy.

10.2    When we update this policy, we will take appropriate measures to notify you of any significant changes we make. We will obtain your consent to any material changes to this policy if and where this is required by applicable data protection laws.

11. Further information / contact

11.1  This website is owned and operated by FIPRA International Limited.

11.2  We are registered in England and Wales under registration number 3936157, and our registered office is at 201 Borough High Street, London SE1 1JA.

11.3  Our principal place of business in Belgium is at 227 Rue de la Loi – 1040 Brussels – BELGIUM.

11.4   If you have any further questions regarding this policy or your data protection rights, you can contact us:

(a)    by post, to FIPRA International, 227 Rue de la Loi – 1040 Brussels;

(b)    by telephone, on +32 26 13 28 11; or

(c)    by email, using: dataprotection@fipra.com

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