Last updated: 24/01/2020
1. About this Notice
1.1 This Privacy Notice (“Notice”) explains how we (as defined below) collect, share and use any information that, alone or in combination with other information, relates to you (“Personal Data”) when you (“you” and “your”) use our website https://popsinwaste.eu/ (the “Website”).
1.2 This Notice also sets out the rights that you have in relation to the Personal Data that we process about you and how you can exercise them.
1.3 RPA (as defined below) treats compliance with its privacy obligations seriously. This is why we have developed this Notice, which describes the standards that RPA applies to protect Personal Data.
1.4 For the purposes of this Notice, Risk and Policy Analysts Europe srl with registered office at Via Filippo Turati 8, 20121 Milan, Italy, (collectively “RPA”, “we”, “us”, and “ours”) acts as the data controller for the Personal Data that is collected via the Website. As a data controller, RPA is responsible for ensuring that the processing of Personal Data complies with applicable data protection law, and specifically with the General Data Protection Regulation.
1.5 Please take the time to read this Notice carefully. If you have any questions or comments, please contact RPA’s GDPR Compliance Officer at firstname.lastname@example.org.
2. What Personal Data does RPA collect and why?
2.1 The types of Personal Data that we may collect about you, and the reasons why we process it, include:
Why we collect it
|Identification data (first name, last name, Email address)||To manage participation in questionnaires||Legitimate interest|
|Email address||To communicate with you and respond to your queries||Legitimate interest|
2.2 We may also collect certain information automatically from your device. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
3. Who does RPA share your Personal Data with?
3.1 We may disclose your Personal Data to the following categories of recipients:
(a) to our company members for purposes consistent with this Notice. We take precautions to allow access to Personal Data only to those members who have a legitimate business need for access and with a contractual prohibition of using the Personal Data for any other purpose.
(b) to our third party vendors, services providers and partners who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Notice or notified to you when we collect your Personal Data. This may include disclosures to third party vendors and other service providers we use in connection with the services they provide to us, including to support us in areas such as IT platform management or support services, infrastructure and application services, marketing, data analytics;
(c) to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
(d) to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose;
(e) to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Notice;
(f) to any other person if you have provided your prior consent to the disclosure.
4. How we protect your privacy
4.1 We will process Personal Data in accordance with this Notice, as follows
(a) Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law.
(b) Purpose limitation: We will process Personal Data for specified and lawful purposes, and will not process it in a manner that is incompatible with those purposes.
(c) Proportionality: We will process Personal Data in a way that is proportionate to the purposes which the processing is intended to achieve.
(d) Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us promptly of any changes or errors. You should notify us of any changes to the Personal Data that we hold about you (e.g. a change of address).
(e) Data security: We use appropriate technical and organisational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
(f) Data processors: We may engage third parties to process Personal Data for and on behalf of RPA. We require such data processors to process Personal Data and act strictly on our instructions and to take appropriate steps to ensure that Personal Data remains protected.
(g) International data transfers: Your Personal Data may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective.
However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Notice. In particular, we only transfer personal data to countries that fall under the adequacy decision of the European Commission or, in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1) GDPR, that provide appropriate or suitable safeguard such as Binding Corporate Rules or Standard Contractual Clauses. More information and a copy of these measures can be obtained upon request.
5. Your data protection rights
5.1 You have the following data protection rights:
(a) If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the following contact email@example.com.
(b) In addition, in certain circumstances, as stipulated in the applicable data protection legislation, you can object to processing of your Personal Data or ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the following contact details firstname.lastname@example.org.
(c) If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
(d) If you have a complaint or concern about how we are processing your Personal Data then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
5.2 We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
6. Linking to other websites
6.1 The Website may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of Personal Data you submit whilst visiting these websites.
We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Data from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us at email@example.com.
8. Updates to this Notice
8.1 We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws.
8.2 You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.
9. How to contact us
9.1 If you have any questions regarding the manner in which we process your Personal Data, or if you wish to exercise your rights, please contact us at the following email address: firstname.lastname@example.org.
9.2 You may also write us at the following address:
RPA Europe srl
Via Filippo Turati 8