The following Additional Privacy Statements (the "Additional Statements") have been added by the Event Organiser and are specific and in relation to this Event ("Global Initiative's Conference Room") only. These set out additional Promotion and Insight activities that are being conducted by the Event Organiser and sets out additional data processing that they expect to do:
The Global Initiative against Transnational Organized Crime group (the GI, “we”, “us”) is fully committed to protecting the privacy and security of your personal data in line with applicable laws. This privacy policy informs you of our policies regarding the collection, use and disclosure of your personal information. Personal information means information from which an individual could be identified, either directly or indirectly. The GI is comprised of the following entities:
The Global Initiative Against Transnational Organized Crime, an association established in Geneva, Switzerland under Articles 60-79 of the Swiss Civil Code, [CHE-296 622. 305] with its registered office at WMO Building, 2nd floor 7bis Avenue de la Paix Geneva, CH-1211, (the “Global Initiative HQ”) The Global Initiative – Verein gegen transnationale organisiert Kriminalität, with its place of residence in Vienna, Austria and its main place of activities in Austria and Southeastern Europe, whose registered office is at Schwarzenbergplatz 1/3rd floor, AT-1010 Vienna/ZVR: 102 464 2959 (the “Global Initiative Vienna”); and The Global Initiative Against Transnational Organised Crime Cape Town NPC, a non-profit company incorporated under section 13(1) of the South Africa Companies Act, 2008 with its registered office at Community House, 41 Salt River Road, Cape Town 7925, South Africa (the “Global Initiative Capetown”. In order to make it easy for you to find out more about how we handle information about you, we have divided privacy notice into two sections. The first section sets out the general information that applies to all individuals whose personal data we use, the second section is divided into specific categories of individuals whose personal information we use so that you can find the most relevant information to you.
The GI entity that is the data controller of your personal data depends on the entity with whom you have a relationship, unless you are a visitor to the website in which case no personal information is collected about you. The specific data controller that handles your personal information is listed in the specific sections below. The data controller determines the purpose and means of how your personal information is used. Personal information means information from which an individual could be identified, either directly or indirectly.
In certain circumstances you have the right to:
Request access to your personal information (often referred to as a ‘data subject access request’), enabling you to receive a copy of the information we hold about you. Request correction of any incorrect or incomplete personal information we hold about you. Request that we erase your personal information where there is no good reason for us to continue to process it. Object to our processing of your personal information where we are using it for our legitimate interests. Request that we restrict our processing of your personal information, for example if you wish to determine its accuracy or why we are processing it. Ask us to transfer certain personal information we hold about you to another third party service provider, or directly to you. If we are relying on your consent to use your personal information, you have the right to withdraw it at any time (we will always provide you with details as to how you can withdraw your consent at the point at which you grant it, and below). Complain to your local data protection supervisory authority (The Federal Data Protection and Information Commissioner in Switzerland, and the Datenschutzbehörde in Austria).
Your personal information will be shared, if appropriate or necessary, with GI group companies, which are limited to the entities listed at the beginning of this privacy notice.
In addition, the GI may share your personal information with third parties of the following types:
third party technological services providers such as providers of emails services, cloud storage or survey structuring; third party service providers of services including insurance, travel logistics, and payroll functions; regulators where required to do so by law. The GI will only share your information with third parties where it is required by law, necessary to administer the working relationship with you, or we have a legitimate interest to do so. Under no circumstances will we sell or rent this information to any third party.
Sometimes when we share your personal information with the third parties described above, it may be transferred to countries outside the European Economic Area. We will do our best to make sure that your personal information is stored and transferred in a way which is secure. When transferring personal information out of the EEA we take appropriate steps to protect that information, which include:
entering into agreements with third parties which include these standard clauses; and transferring to third parties that have agreed to comply with schemes approved by the European Commission to protect your information, or in jurisdictions which the European Commission has decided provide adequate protection for your information (Switzerland, where one of the GI entities is based, is a jurisdiction that has been deemed to provide adequate protection in this way). 4. How do we keep your information safe
The security of your Personal Information is extremely important to us, and so we take appropriate technological and organisational steps to keep your personal information safe. The GI also carefully selects all the technology service providers it uses, giving due consideration to the technological security measures which are applied to the information used by them.
Please remember that no method of transmission over the internet or method of electronic storage, is 100% secure. Should you suspect or be concerned about a breach relating to your data, please contact us immediately.
This Privacy Policy was last amended in August 2019, and it may change from time to time where required. Please ensure you check back regularly to keep updated.
If you have any concerns about how we use your personal information, or would like to exercise any of the rights to which you are entitled, as listed above, please contact Johana Borstner at ([email protected]).
If your query relates to a specific event, or to the newsletter, please contact Claudio Landi ([email protected]).
If your query relates to the GI network, please contact Livia Wagner ([email protected]).
HeySummit is not responsible for any part of the above Additional Statements and is only responsible for the Core Privacy Statements set out hereunder:
The following Core Privacy Statements (the "Privacy Statements"), together with the Core Terms of Service and any other documents referred to herein set out we will use the data you provide us at heysummit.com and/or app.heysummit.com (the "Platform") and what Insight activities are ongoing there too.
Please read these Privacy Statements carefully and ensure that you understand them. You will be able to change your Privacy Preferences at any time throughout your time using the Platform and thereafter.
HeySummit’s purpose in establishing this Privacy Statement is to give you information about how HeySummit collects and processes your personal data through your use of the HeySummit Services, including any data you may provide through the HeySummit platform. If you do not agree with the terms, do not access or use the HeySummit Services, websites or any other aspect of HeySummit’s business.
This Privacy Statement applies to all users of HeySummits Platform and associated technology. It is important that you read this Privacy Statement together with any other Privacy Statement or fair processing policy we may provide on specific occasions when we are collecting, or processing, personal data about You, so that you are fully aware of how and why we are using your data. This Privacy Statement supplements other notices and privacy policies and is not intended to override them.
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. HeySummit and Event hosts are independent controllers of certain types of your personal data, such as your registration data (like name and email) and attendance data (like Event name, date and time of Event, and Event sessions attended). Event hosts are the controller, and HeySummit is the processor of Event data, such as information and materials submitted to, or during an Event.
We keep our Privacy Statement under regular review and it may be updated periodically. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will notify you by posting an updated, date-stamped version of this Privacy Statement on our website. If we make changes that materially alter your privacy rights, we will provide notice to you in accordance with applicable law. Notice may be by posting a notice on our website, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law. Accordingly, please keep your account information, including email address, updated.
The HeySummit Services include links to third-party websites and applications as well as to partner providers of multiple different types of services associated with a particular Event.
Clicking on links to third party websites, content or applications may allow those third parties to collect or share data about you. We do not control those third-party websites or content and are not responsible for their privacy statements or the way in which they collect or use your data.
Where you access or use third party services provided by an Event organiser, advertiser, sponsor or any other party who participates in an Event, we encourage you to request details of and read the Privacy Statement of that party. We do not control those third parties and are not responsible for their privacy statements or the way in which they collect or use your data.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifying information has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with access to the HeySummit Services).
We use different methods to collect data from and about you including through:
The legal basis for using your information as set out in this Privacy Statement are as follows:
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a user of the HeySummit Event Platform |
(a) Identity (b) Contact |
Performance of a contract with you |
To process any paid entry to an Event:
(a) Managing payments, fees and charges (b) Verifying your identity and details of your payment method or credit card account (c) Communicating with you, for example sending you confirmation of your attendance for an Event. |
(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests |
To manage our relationship with you which will include: (a) Providing access to Platform services (b) Notifying you about changes to our terms or Privacy Statement (c) Asking you to leave a review or take a survey (d) Investigating complaints |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use the HeySummit Event Platform and associated products/services) |
To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, administering our CRM, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how users use the HeySummit Event Platform and to grow our business and inform our marketing and growth strategy) |
Share your information to support the Host or Event Organiser or Team Member(s) to create, manage and deliver the Event. |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
To provide our own services as per our collective agreements and support the Event Organiser to conduct their agreements with you. |
To use data analytics to improve our Platform, products/services, marketing, user and Partner relationships and experiences. |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of users for certain Platform services and to keep our services and web site updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about Events or other services available through the HeySummit Event Platform that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop the products and services available through the HeySummit Event Platform) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may opt out of any non critical marketing communications but some communications are directly related to the provision of our Services.
Recommendations from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which services and offers may be relevant for you. Subject to applicable law, we may send you information that we think may be of interest to you.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time. You can contact us or, where applicable, use the instructions located at the bottom of your email. Please note that regardless of your request, we may still use and share certain information as permitted by this Privacy Statement or as required by applicable law. For example, you may not opt out of certain operational communications, such as those reflecting our relationship or transactions with you.
Cookies
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the HeySummit Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Advertising and Analytics Services Provided by Others
We may allow others to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the HeySummit Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by HeySummit and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the HeySummit Services and other websites and better understand your online activity.
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 and that reason 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. 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.
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
Where third parties provide Events or support the provision of Services made available to you, these third parties may receive certain personal data about you. Whilst we are not in control of these third parties, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.
To help constantly improve and tailor the service we provide to you, we may use aggregated information so that we can administer and improve our services, analyze trends, gather broad demographic information and detect suspicious or fraudulent transactions and most importantly monitor and improve our operations on a day to day basis. In carrying out this activity, we may pass some information to third parties in aggregate and anonymized format.
Your disclosure to third parties
Except as otherwise expressly included in this Privacy Statement, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, different rules may apply to their use or disclosure of the information you provide to them. HeySummit does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.
We may transfer your personal data outside your country of residence, including the European Economic Area (EEA), in our performance of services.
Whenever we transfer personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place commercially reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other 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. That said, no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or as required or permitted by applicable law.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
If you provide personal data in connection with the submission of Event Content, we may process sensitive personal data as part of the HeySummit Services.
This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month or within the timeline provided by applicable law. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this Privacy Statement or our privacy practices, including any requests to exercise your legal rights, please contact us as follows:
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). You may also direct your complaint or concern to your applicable data protection authority. We would, however, appreciate the chance to address your concerns before you approach the ICO or another data protection authority.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to HeySummit, that is the performance of our agreement with you to make the HeySummit Services available. We are not involved in the processing of your Personal Data during any engagement you enter into with our third party partners.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
Requests to exercise your rights may be submitted by emailing us at [email protected] Please be prepared to provide your first and last name and email address that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.
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