Harm Reduction International (“we”, “our”, “us” or “HRI”) is committed to protecting the privacy of all users of our website hri.global, or our online conference registration site (together, the “Sites”). This privacy notice explains your rights as an individual, how we use and protect your information. We’ll be the “data controller” of the information you provide to us.
1. CONTACT DETAILS
If you have any queries or requests concerning this privacy notice or how we handle your data more generally, please get in touch with us using the following details.
By contacting our office at: email@example.com
By contacting our Data Protection Officer: firstname.lastname@example.org
2. HOW WE COLLECT YOUR INFORMATION
We collect your personal information when you interact with us or use our services, such as when you use our Sites to subscribe to email updates or to register to attend our conference or an HRI event.
We also look at how visitors use our Sites, to help us improve our services and optimise customer experience. When someone visits the Sites we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
We collect information:
- when you create an account with us or you change your account settings;
- subscribe to email updates;
- sign up to be a ‘supporter’ or donate;
- when you apply for a job or consultancy; and
- when you contact us directly via email, phone, post or message (including as part of work
- related to our research, advocacy, policy work, partnerships, programmes and projects).
3. INFORMATION THAT WE COLLECT FROM YOU
As part of our commitment to the privacy of our conference delegates and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you.
When you visit the Sites or sign up or register through the Sites, you are asked to provide information about yourself including your name, contact details, and (where required) payment information such as credit or debit card information.
We also collect information about your usage of the Sites and information about you when you contact us or provide us with feedback, including via e-mail, letter or phone. If you contact us by phone, we may make notes in relation to your call.
We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.
4. USE OF YOUR INFORMATION
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.
Where we need to, in order to provide you with the service you have requested or to enter into a contract, we use your information:
- to enable us to provide you with access to the relevant parts of the Sites;
- to supply the services you have requested;
- to enable us to collect payment from you; and
- to contact you where necessary concerning our services, such as to resolve issues you may have with your registration.
We also process your data where we have a justifiable reason for doing so— for example personalisation of our service, including processing data to make it easier and faster for you to place register. We have listed these reasons below:
- to improve the effectiveness and quality of service that our conference delegates can expect from us in the future;
- to tailor content that we display to you, for example so that we can show you events or reports that may appeal to you, based on characteristics determined by us;
- to enable our team to help you with any enquiries or complaints in the most efficient way possible;
- to contact you for your views and feedback on our services and to notify you if there are any important changes or developments to the Sites or our services where you have asked us to do so;
- to analyse your activity on the Sites so that we can administer, support, improve and develop our charity and for statistical and analytical purposes and to help us to prevent fraud;
- to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of HRI or others (including to prevent fraud); and if you submit comments and feedback regarding the Sites and the services, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you live.
Where we rely on legitimate interest as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. You can find out more information about these balancing tests by contacting us using the details above.
Where we are under a legal obligation to do so we may use your information to:
- create a record of your registration(s);
- comply with any legal obligation or regulatory requirement to which we are subject.
5. JOB/CONSULTANCY APPLICANTS
1. HRI is the data controller for the information you provide during the employment/consultancy process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at email@example.com.
2. All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
3. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us whether the information is in electronic or physical format.
4. We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the job/consultancy you have applied for.
5. We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
6. If you are successful, the information you provide during the application process will be retained by us as part of your file for the duration of your employment/consultancy plus six years following the end of your employment/consultancy. If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for one year from the closure of the job/consultancy advertisement. Equal opportunities information is retained for six months following the closure of the campaign whether you are successful or not.
6. DIRECT CONTACT WITH YOU
Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know about our other products and services that may be of interest to you and we may contact you to do so by email or phone.
You can control your email marketing preferences by:
- visiting our Sites, hri.global or hr19.global ;
- clicking on “Account” (for our website this is under the drop-down menu); and
- scrolling down to “Contact Preferences”.
7. RETENTION OF YOUR INFORMATION
We will not retain your information for any longer than we think is necessary.
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘Use of my information’ section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on ‘How we use your personal information’ above);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
8. DISCLOSURE OF YOUR INFORMATION
The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with.
Sharing your information with third parties
We share your information with third party service providers. The types of third party service providers whom we share your information with includes:
- Payment providers (including online payment providers and fraud detection providers): for the purposes of providing services to us, for example when they process information such as credit card payments for us, provide support services to you or carry out fraud checks for us;
- IT service providers (including cloud providers): for the purposes of data storage and analysis;
- Mailchimp and/or other email management service providers;
- Service companies: for the purposes of conference registration.
HRI will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice when it is transferred to third parties.
We may also share your information:
- if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention;
- in order to enforce our contractual terms with you and any other agreement; and
- to protect the rights of HRI or others, including to prevent fraud.
We adopt robust policies to ensure the personal information we hold about you is suitably protected.
We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. YOUR RIGHTS
Under data protection law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact our Data Protection Officer using the contact details set out above. For additional information on your rights please contact your data protection authority and see below.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this notice.
The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us (see Contact Details).
The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us (see Contact Details).
The right to restrict processing. You have rights to ‘block’ or ‘suppress’ further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).
The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority.
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by changing your marketing preferences or disabling cookies as set out in sections 7 and 8 above.
11. CHANGES TO OUR PRIVACY NOTICE
Any changes to our privacy notice will be posted to the Sites and, where appropriate, we will notify you of the changes for example by email.
This privacy notice was last updated: 24/05/2018
If you want to make a comment or complaint about the way we have processed your personal information, you can contact us via firstname.lastname@example.org.