Last updated: May 25 2020
HAMA Europe (“HAMA”, “we“, “us” or “our”) are committed to protecting and respecting your privacy. This policy together with our Cookies Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (the “GDPR”), the controller of your personal data is HAMA Europe ofSuite 1, 3rd Floor, 11-12 St. James’s Square, London SW1Y 4LB UK.
If you wish to contact us with any questions in relation to this policy or our privacy practices, you may contact us in writing the address given above or by emailing email@example.com.
Information we may collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect and process the following data about you:
Identity data: name, gender and date of birth;
Contact data: postal address, email address and telephone number;
Employment data: job title, employment history and experience (pursuant to your application);
Financial data: financial details when you pay a membership or application fee or other applicable sum, for example by making payment using our website, wire transfer or cheque;
Technical and usage data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
We may collect this information from you when you:
engage with us to provide you with our services;
complete and submit a membership application;
contact us via email, mail or telephone with any query;
attend one of our events (as an attendee, sponsor, speaker);
participate in one of our Awards; or
provide us any feedback on our services or sites.
As you interact with our website, we will also automatically collect the technical and usage data noted above about your equipment, browsing actions and patterns. We collect this personal data by using cookiesand other similar technologies.For more information, please see our Cookies Policy.
How we use your personal data
We use your personal data for the following reasons:
to provide you with our services, namely membership with HAMA;
to send you marketing materials;
to invite you to attend events;
to record your attendance at events;
to provide you with any purchase you have made; or
to respond to any of your queries.
We only process your personal data when it is lawful for us to do so. We rely on the following lawful grounds to process your personal data:
consent of the data subject, for example to send you marketing communications;
performance of a contract to which the data subject is party or in order to take stepsat the request of the data subject prior to entering into a contract, for example the terms governing your membership if you are a member as an individual;
compliance with a legal obligation to which the controller is subject, for example any obligations to which we are subject relating to the acceptance of payments; and
legitimate interests pursued by the controller or by a third party, for example if we share your personal information with an event holder, or potentially to market to you depending on the circumstances, or if we legitimately believe it is beneficial for the growth of HAMA. We will never use your personal data for our, or a third party’s, legitimate interests if your interests override ours and will always carry out a balancing test to establish this.
Sharing your personal data
We may share your personal data in the following scenarios:
We may share your personal data with your consent, for example with event/webinar speakers or other attendees.
We may share your personal data with certain service providers or group companies to help us provide the best services to you and others, for example our data storage providers.
We may share your personal data if we are required to respond to law enforcement, officials, regulatory agencies and other lawful requests or legal processes, or to comply with a legal obligation to which we are subject.
Certain of the above listed third parties or group companies may bebased outside the European Economic Area (EEA), namely our service providers, so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Security of your personal data
We take your privacy very seriously and work hard to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place appropriate security measures to prevent this from happening. In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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 your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
How long we keep your 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 or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
In certain circumstances, you may have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal data.
Complain to a data protection authority regarding any data protection issues. Within the UK, the Information Commissioner’s Office (the “ICO”)is the data protection authority. We would, howeverappreciate the chance to deal with your concerns before your approach the ICO, or another data protection authority, so please contact us in the first instance.
To exercise one of the above rights, please contact us using the details provided above.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. 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.
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