We set out below how the Arbitration Association of Central and Eastern Europe, z.s., registered with the Register of Associations kept by the Municipal Court in Prague, under identification number 194 01 914 (“ArbCEE”, “we’, “us”) collects and processes your personal data as a data controller (within the meaning of regulation (EU) 2016/679 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 (General Data Protection Regulation or GDPR) for the purposes of is activities.
This Privacy Notice is addressed to members of ArbCEE, its business partners, contact persons, newsletter recipients and visitors of the ArbCEE website.
This Notice is in effect as of the date indicated at the end of this Notice. If we make any changes to it, we will change the date and update this Privacy Notice on our website.
If you have any questions about this Privacy Notice, how we process your personal data or want to exercise any of your data subject rights, please refer to the details found at the end of this Notice.
WHAT PERSONAL DATA DO WE COLLECT AND HOW DO WE COLLECT IT?
Depending on the circumstances, we may obtain the following personal data about you:
- basic information, such as your name (including any titles), the company you work for, your title or position, your gender, your date of birth, your place of residence;
- contact information, such as your postal address, email address and phone number;
- financial information, such as payment-related information;
- technical information, such as information from your visits to our website (including in particular your IP address) or in relation to materials and communications we send to you electronically;
- information you provide to us for the purposes of attending any events or meetings, including accessibility and dietary requirements;
- identification and background information provided by you in the application for membership or collected as part of our membership admission processes;
- any personal information provided to us in the course of providing services in relation to membership and events;
- biographies, cover letters and employment history;
- profile pictures and photos taken at events;
- a record of correspondence via email and social media.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose and in line with the GDPR. 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 or ask you for your consent.
We might use information held about you in the following ways, with the list not being exhaustive:
- when you join or apply to join as a member of ArbCEE or any of its sub-divisions;
- in the provision of our membership services to you or to others;
- to contact you regarding our membership services, including sending legal updates, publications and details of (online and in person) events or meetings;
- to provide and improve our website, including auditing and monitoring its use;
- to fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims; or
- for the purposes of recruitment.
WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
There are a number of different ways in which we are lawfully able to process your personal data. We have set these out below.
We are able to lawfully process your data under Article 6(1)(b) of the GDPR, which states that we can process your data where this processing “is necessary for the performance of a contract to which [you] are a party“. We therefore rely on this legal basis to collect and otherwise use your personal data to enable us to perform our part of our contract with you and our obligations to third parties, and to ensure that you are properly fulfilling your obligations to us.
As well as our obligations to you under our contract, we also have other legal obligations that we need to comply with. Article (6)(1)(c) of the GDPR states that we can process your personal data where this processing “is necessary for compliance with a legal obligation to which [we] are subject“.
Article 6(1)(f) of the GDPR explains that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data“.
We consider the processing activities in our legitimate interest to include the following:
- to help us know and understand our members better and provide better, more relevant information and membership services to them;
- to enable effective networking among members;
- to promote our events and events of our members;
- to promote members with arbitral institutions;
- to ensure our website runs smoothly;
- to help us keep our systems secure and prevent unauthorised access or cyber-attacks.
In very limited circumstances, we are required to obtain your consent before we can undertake certain processing activities with your personal data.
We have asked you to give such consent to certain processing activities in the application for membership.
You have the right to withdraw your consent at any time.
HOW DO WE SHARE YOUR PERSONAL INFORMATION?
Your information will not be disclosed to third parties outside of ArbCEE, except to the following limited categories of recipients:
- third party service providers who perform functions on our behalf (including external consultants, IT service providers and professional advisers such as lawyers, auditors and accountants);
- third parties including financial institutions or law enforcement agencies, where necessary to comply with our legal obligations, our contract with you or where it is otherwise in our or a party’s legitimate interests to do so;
- if we have to disclose or share your personal data if we believe that such action is necessary to protect and defend the rights or property of ArbCEE; and
- third parties involved in hosting or organising events or webinars.
WHERE DO WE TRANSFER YOUR PERSONAL DATA?
In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you reside. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.
FOR HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
Your personal information will only be retained for as long as is reasonably necessary in the circumstances. Retention periods vary depending on the category of data, taking into account legal and regulatory requirements, limitation periods for taking legal action, good practice and ArbCEE’s objectives.
WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL DATA?
The GDPR and other applicable data protection laws provide certain rights for data subjects. You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You may also have the right to lodge a complaint in relation to ArbCEE’s processing of your personal data with a local supervisory authority.
If you object to the processing of your personal data, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above or that you may not be able to make use of the services and events organised by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal data to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We must ensure that your personal data is accurate and up to date. Therefore, please advise us of any changes to your information by email to contact@ArbCEE.org.
If you wish to exercise any of these rights, or if you have any questions about this notice, how we treat your personal data, or wish to exercise any of your data subject rights, you can contact us at contact@ArbCEE.org or by post at:
Arbitration Association of Central and Eastern Europe, z.s.
For the attention of Data Protection Officer
110 00 Prague 1