Privacy policy

(Ver. 20190603)

In this Privacy Policy, Regions4 Sustainable Development (“Regions4”) is referred to as “we/our/us”. This Privacy Policy informs you about how we use any personal data which you provide to us. We are committed to protecting and respecting your privacy, in accordance with the laws and regulations of Belgium (“applicable laws and regulations”), in particular the EU General Data Protection Regulation of 27 April 2016 (“GDPR”) and the Belgian loi relative à la protection de la vie privée à l’égard des traitements de données à caractère personnel of 8 December 1992 (“LPVP”).

1. Our role as data controller

When we use personal data about you or others in connection with promoting and administering our network or providing our services, we do so as data controller.

The data controller is Regions4, a Belgian non-profit international association with registered offices at Chaussée d’Alsemberg 999, 1180 Brussels (Belgium).

2. Your role in keeping your personal data up to date

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

3. Contact details of our Privacy Manager

We do not meet the criteria for a mandatory appointment of a Data Protection Officer under the applicable laws and regulations. We have therefore allocated responsibility to a person in our network who can deal with any data protection-related matters. You can contact our Privacy Manager by email at: privacy@regions4.org marking the subject line, ‘For the attention of the Privacy Manager’.

4. Categories of personal data we process

Personal data, or personal information, means any information relating to an identified or identifiable natural person, directly or indirectly. We may receive different kinds of personal data about you, from you and from third parties (for example, a publicly available source). We have grouped this information together as follows:

• ID/Contact Data. This is data such as your name, date of birth, nationality, passport or ID number, handwritten signature, email address, telephone/fax number, address or other contact details.
• Correspondence/Transcript Data. This is data such as correspondence between us, notes of our calls and meetings, transcripts of audio recordings or quotes from statements you made.
• Work Data. This is data such as your employing government or organisation, your department, job function, employment history or qualifications.
• Audio/Video Data. This is data such as pictures or audio, video or screen activity recordings.
• Social Media Data. This is data such as your Facebook or Twitter account name.
• Financial Data. This is data such as your bank or tax details.
• Transaction Data. This is data such as details about your expenses and any payments to and from you.

5. Purposes for processing personal data

Our core purposes for processing personal data are to promote and administer our network, provide services to you and comply with the laws and regulations. In relation to you (or the organisation you represent) this involves: communicating with you;  building capacity; raising funds; reporting on our work; conducting surveys; concluding agreements/commitments and keeping records thereof; registering you at events, making travel arrangements for you, providing financial support to you for participating to events, and introducing you at events; prospecting; keeping records; concluding service contracts; recruiting staff; making payments; and managing our contacts.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Contract. Where it is necessary for us to perform a contract which we are about to enter, or have entered, with our service providers or with you for us to provide services to you.
• Legitimate interests. Where it is necessary to our legitimate interests and your interests or fundamental rights and freedoms do not override those interests.
• Legal obligation. Where we need to comply with a legal or regulatory obligation.

6. Legal bases for processing personal data

This table sets out in more detail the legal bases we rely on to process personal data, depending on the category of personal data and the reason we are processing it. Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data.

7. Sharing personal data

We may:

• allow our staff to access your data to promote and administer our network and provide services to you;
• share your data with our members and partners, e.g., to communicate, conclude agreements/commitments, register you and introduce you at events, raise funds and promote our network;
• share your data with travel agencies, flight companies and hotels to make travel arrangements for you;
• share your data with third-party service providers to whom we outsource certain tasks, such as IT or business administration;
• share your data with our bank and tax and accountancy consultancy, e.g., to make payments;
• share your data with our tax and accountancy consultancy to fulfil our accounting requirements.

We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will not otherwise share personal information with any third party except where we are required to by law.

8. International transfers

We use service providers that may store your data or share it with third parties outside the European Economic Area (EEA), which includes the Member States of the European Union (EU), Iceland, Norway and Liechtenstein. Whenever we do so, we make sure that these service providers comply with the rules in the GDPR, in particular by using one of the standard mechanisms provided for transfers to third countries, i.e., non-EEA countries, such as:

• Adequacy decision, i.e., a decision by which the European Commission deems a third country or an international organisation ensures an adequate level of protection;
• Appropriate safeguards, such as binding corporate rules, standard data protection clauses adopted by the European Commission or contractual clauses between the service provider and the third party authorised by the competent supervisory authority;
• Other safeguards, such as explicit consent, for transfers not covered by any of the above mechanisms.

We also sometimes share data with members, partners or service providers located in third countries, where privacy laws may not be as protective as those in the EEA. In order to transfer your data outside the EEA we will use one of the abovementioned mechanisms.

9. Safeguarding personal data

We have put in place appropriate technical and organisational security measures to safeguard your personal data.

10. Data storage and retention

We store data digitally and in hard copy, and we keep it for 48 months after the purpose for which it was collected has been fulfilled (e.g., to prevent fraud, resolve disputes, troubleshoot problems), save when a longer retention period is required by law.

11. Your rights

If the GDPR applies to you, you have the following rights:

• Right of access. You can 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.
• Right to rectification. You can request rectification of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected.
• Right to erasure. You can request erasure of your personal data. This enables you to ask us to delete or remove personal data in the following scenarios: (a) where there is no good reason for our continuing to process it; (b) where you have withdrawn consent on which the processing was based; (c) where you have successfully exercised your right to object to processing (see below); (d) where we may have processed your information unlawfully; or (e) where we are required to erase your personal data for compliance with a legal obligation. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to restriction of processing. You can request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) where you contest the data’s accuracy, for a period enabling us to verify its accuracy; (b) where our use of the data is unlawful, but you oppose its erasure and request its restriction instead; (c) where we no longer have a use for the data, but you need us to hold it as you need it to establish, exercise or defend legal claims; or (d) where you have objected to our use of your data (see below), but we need to verify whether we have compelling legitimate grounds to use it which override your interests, rights and freedoms.
• Right to object. You can object to processing of your personal data where we are relying on our legitimate interests (or those of a third party), on grounds relating to your particular situation. We shall no longer use your data, unless we demonstrate that we have compelling legitimate grounds to process your data which override your interests, rights and freedoms.
• Right to withdraw consent. You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Right to make a complaint to the supervisory authority. You have the right to lodge a complaint with the supervisory authority at any time (see below).

If you wish to exercise any of the rights set out above, please contact the Privacy Manager.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded or excessive, we may charge a reasonable fee or, alternatively, refuse to comply with your request.

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 try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you.

12. Supervisory authority

With regard to data protection, we are supervised by the Data Protection Authority of Belgium (“DPA”). You can find out more about the DPA through its website: https://www.dataprotectionauthority.be/. We would be happy to answer your questions and address your concerns regarding our use of your data. Please email us at privacy@regions4.org and mark the subject line, ‘For the attention of the Privacy Manager’. Please also use that address for any requests to exercise your legal rights or if you have a complaint. Alternatively, you have the right to make a complaint to the DPA at any time, but we prefer you to contact us first. We should be able to resolve the matter quickly and to your satisfaction.

13. Source of the personal data

Most of the personal data we process will be obtained directly from you, but we may also acquire personal data about you from other parties connected with you. We also get data from publicly available sources.

14. Failure to provide personal data

You are not under any obligation to provide personal data to us. However, if we need personal data to undertake the core task of promoting and administering our network or providing our services to you, and you do not provide this information, we may not be able to do so. If this happens, we will inform you.

15. Updating our Privacy Policy

We update this Privacy Policy when necessary or in response to:

• Feedback from data subjects, regulators or other stakeholders.
• Changes in our data processing activities or policies.

When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of the Privacy Policy. If there are material changes to the Privacy Policy, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect on our website or by directly sending you a notification. We encourage you to periodically review this Privacy Policy.

Last update: 3 June, 2019.