Privacy Policy
last update 09 September 2024
EFAE (hereafter ‘we’) commits to respect the privacy of its members and other contacts.
This page informs you on our policies regarding the collection, use and disclosure of personal information (further ‘Personal Data’) we receive from users of our website www.efae.eu (called hereinafter the ‘Site’).
EFAE staff is informed of the importance of data protection and is consulted on following the appropriate steps to respect privacy, confidentiality and security of your Personal Data.
Your privacy protection is important to us. This is why we have adopted the following pivotal legislation: EU’s General Data Protection Regulation 2016/679 (“GDPR”) and the Italian Legislative Decree 196/2003 (“Personal Data Protection Code”) as amended by Legislative Decree 101/2018, and, where relevant, the provisions issued by the Guarantor for the Protection of Personal Data. This Privacy Notice relates to all personal data we process and addresses the legislation mentioned.
Please be aware that data transfer via the internet is subject to security risks, and, therefore, we cannot guarantee a complete protection against third-party access to transferred data.
In order for us to provide you with our services or for correspondence purposes, we need to collect your personal data. We ensure that the information we collect and use is confined to this purpose. We always process your personal data for specific purposes, with the nature of the data collected depending on your interaction with us. We are committed to transparency in this.
Our legal bases for controlling or processing personal data are:
Article 6.1(a) GDPR (Consent): You provide informed consent to us or have a reasonable expectation that we will use your information in a certain way – for example, to engage in our community discussions, or to hear about new services or offers. You can withdraw your consent at any time by requesting it to privacy@efae.eu or info@efae.eu
Article 6.1(b) GDPR (Contract): Providing our services and fulfilling our obligations to you, usually relating to terms of service or agreement;
Article 6.1(c) GDPR (Legal Obligation): The necessity to meet compliance with our legal obligations; and/or
Article 6.1(d) GDPR (Legitimate Interest): Where it is in our legitimate interests to do so. We only rely on ‘legitimate interests’ as the legal basis for processing by us, or third parties we use, for these purposes:
Recruitment and induction of new employees, contractors and other people who work with us;
Registering new participants to the EFAE programs;
Emergency contacts for people who work with us, such as employees and contractors for health and safety purposes;
Business development; or
Where we rely on a specific basis for processing your information and you wish to object to that processing, you must be aware that it might not be possible for you to continue using our services.
The special categories of personal data (Article 9 of GDPR) we process are:
Health data in respect of employees, contractors and other people who work with us; and/or any special categories of special personal data, which any user volunteers while using our services (for example in a forum or submission).
If we need to pass on special category personal data (see Article 9 GDPR) to a third party, we will only do that in accordance with the legal bases under Article 6 of GDPR as outlined above.
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Purposes of collecting and using Personal Data
We collect personal information you provide to deliver different services (called hereinafter the ‘Service’) such as newsletters, updates regarding your membership benefits and duties, information on our events (including those you subscribed to), publications, advocacy campaigns and other projects. The data are collected based on EFAE’s legitimate interest to inform you about our activities and/or based on your prior consent.
Therefore, we collect and use Personal Data to provide and maintain the Service; to notify you about changes to our Service; to allow you to participate in the Service and to support you when doing it; to provide analysis or valuable information so that we can improve the Service; to monitor its usage. Moreover, we collect Personal Data to improve your user experience in relation to the Site.
Types of data collected
While using our Service, we may ask you to provide us your Personal Data that can be used to contact or/and identify you. Personal Data may include, but is not limited to: your name, email address, address, current employer and job title.
Event participation
When registering or applying for our events you may be asked to provide us with your CV, passport or ID card, travel schedules, accommodation preferences, meals preferences, and accessibility requirements.
If you register for one of our events, we assume that you agree to be photographed and/or videotaped during that event, unless you express your disagreement by sending us an email to privacy@efae.eu or info@efae.eu one day before the start of the event. The pictures and videos from the event will be published on our Site, social media channels, newsletters, and meeting reports, and may be used for promotion of our activities. Even if you did not express your disagreement prior to the event you can always contact us afterwards to request any photo of you to be removed or deleted. To exercise this right, please contact us via email: privacy@efae.eu or info@efae.eu
How we collect personal data
Here we give you examples of ways that you interact with us and the resulting data we may collect!
EFAE collects personal data from you when you interact with us. This can be through our website, over telephone, in person, including, without limitation, when you:
Request support;
Register for or participate in an online class, certification, training, webcast or other EFAE event, program and course;
Request information or materials;
Participate in surveys or evaluations;
Submit questions or comments; or submit content or posts on our forums or other interactive webpages.
How we use personal data
Here we let you know what happens if we need to engage others to assist us to service your needs. If we do engage others we have set how we ensure your data is kept safe.
We may need to pass your personal data on to third-party service providers contracted to EFAE in the course of dealing with you. We do this because there are services which will not work unless we are able to make these transfers. Any third parties we share your data with are obliged to keep your personal data secure and use it only for necessary service delivery. When your data is no longer required to fulfill the service, those third parties will be directed to dispose of your data in accordance with our standard procedures.
Transmission and disclosure of your data to third parties
We do not sell personal data.
Moreover, your Personal Data can be transferred to a third party, namely:
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Sub-contractors, co-organizers and supporting partners engaged in the framework of the strategy and mission of EFAE; or
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Competent authorities or any other legal entities to fulfill legal obligations or for purposes of law enforcement; or
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If you consent to it.
These third parties have access to your Personal Data only to perform strictly agreed tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Our third-party Service Providers, such as wix.com, brevo (ex sendinblue), google contacts, among others, have committed to bring their privacy policies in line with the legal requirements.
Some Personal Data, such as your first and last names, organization, position and country will be shown on your public profile on the Site, on the contacts directory or/and on the participants’ list of the events to which you subscribe. We do not publish email addresses either online or on printed participants’ lists.
How we store personal data
Here we outline our processes for data storage, how we will protect your data and keep it only for as long as needed!
We will process (collect, store and use) the information you provide in a manner compatible with GDPR. We maintain physical, organizational and technical safeguards for all personal data we hold. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain certain information in accordance with the law, such as information needed for tax and audit purposes.
How long certain kinds of personal data should be kept are governed by specific business-sector requirements and agreed practices. Depending on individual business needs, personal data can be held in addition to these periods. We will process different forms of personal data for as long as it is necessary and proportionate for the purpose for which it has been supplied and we will store the personal data for the shortest amount of time possible, taking into account legal and service requirements.
Data protection rights
You control the personal data you share with us! Here, we outline your rights under GDPR.
At any point while we are in possession of or we process your personal data, you have the following rights:
(GDPR) right of access – you have the right to request a copy of the information that we hold about you;
(GDPR) right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete;
(GDPR) right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records;
(GDPR) right to restriction of processing – where certain conditions apply to have a right to restrict the processing;
(GDPR) right of portability – you have the right to have the data we hold about you transferred to another organization;
(GDPR) right to object – you have the right to object to certain types of processing such as direct marketing;
(GDPR) right to object to automated processing, including profiling;
(GDPR) right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why.
Controlling your personal information
You can learn what Personal Data we have about you by contacting us at privacy@efae.eu or info@efae.eu or you can please make your request directly to the Data Protection Officer, we will provide you with the response within 14 working days. If you believe that the information we are holding about you is incorrect or incomplete write us at privacy@efae.eu or info@efae.eu . We will make necessary amendments as soon as possible. You can update or delete the accessibility details, that you might add to your account when registering to our events, at any moment.
If you want your data to be completely removed from our database, please send us a request at privacy@efae.eu or info@efae.eu. If you want to stop receiving our newsletters and other mailings, please use the unsubscribe button which can be found on the bottom of each communication.
You have the right to file a complaint with a supervisory authority, in particular in the Member State of your residence, if you consider that the processing of your personal data infringes applicable data protection law.
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Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Meta Pixels
We use Meta Pixels to better understand our audience and deliver more relevant content and advertising to our visitors. It is a tool that helps us measure the effectiveness of our advertising by understanding the actions that visitors take on our website. This includes data such as page views, clicks, and conversions.
We may also use the Meta Pixels to create custom audiences for our advertising campaigns, which means that we may target ads to users who have previously interacted with our website or have similar interests.
Children and Personal Data
Let’s keep our children safe!
Here at EFAE we understand the importance of protecting the personal data of children under the age of 15. It is not our intention to collect personal data from a child. If you believe that a child has disclosed personal data or that we hold personal information about a child, please email us at privacy@efae.eu or info@efae.eu
Verification
Before we action a request we need to ensure it is from you.
Before we action a personal data request we need to verify your identity. We sometimes require additional information such as a color copy of your passport, driving license or national ID card.
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Amendments to our Privacy Notice
We are transparent about any updates made to this Privacy Notice.
EFAE updates this privacy notice when necessary or in response to:
Feedback from our community, relevant authority, industry or other stakeholders;
Changes in our services; and/or data processing or policy changes.
The “last updated” date at the top of this Privacy Notice reflects when the most recent changes were made. We encourage you to periodically review this Privacy Notice for any amendments.
How to contact us
If you have any questions about our Privacy Notice, please contact us via our website contact webpage or by email at privacy@efae.eu or info@efae.eu.
How to contact the appropriate authorities
If you have questions or wish to lodge a complaint about how your personal data is being processed by us (or third parties as described above), or how your complaint has been handled, you have the right to contact our Data Protection Officer.
Data Controller and Data Protection Officer
Data Controller: ETS European Festival of Ancient Greece APS, via Campegna 5b, 80124 Napoli in the person of the legal representative pro tempore.
Data Processor: for further information, please contact: privacy@efae.eu
You can contact the DPO Mr. Valentino Berton under the following:
e-mail Address: privacy@efae.eu or info@efae.eu
Phone: +39 339 3369837
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