Last updated: 8 October 2018
Dialogue Advisory Group (“DAG” or “we”) are committed to protecting and respecting your privacy. We are a non-profit organisation based in Amsterdam, the Netherlands. For the purpose of the General Data Protection Regulation (the “GDPR”), we are the data controller.
This policy sets out the basis on which we will process personal data and use information we collect from you, or that you provide to us, in connection with your use of our websites: www.dialogueadvisorygroup.org and www.amsterdamdialogue.org (the “Websites”). Please read this policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this policy in general or any part of it, you should not access the Websites.
1. What types of information do we collect and how do we use it?
1.1 Information you give us. You may provide information by contacting us via email, telephone, social media or otherwise.
1.2 Information we collect about you. We automatically collect certain data from you when you access the Websites, including IP address or other unique device identifiers and information regarding your use of our Websites such as page views.
1.3 As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our organisation, we will use your information:
– to communicate with you;
– to provide you with the advice, services or information you have asked for;
– for our own internal administrative purposes and to keep a record of your relationship with us;
– to provide you with information about us, our activities, and any other information, products or services that we provide or provide access to;
– to improve our service by contacting you for feedback; or
– to comply with applicable laws and regulations, and requests from statutory agencies.
2. Technical usage information
2.1 When you visit the Websites, we automatically collect the information sent to us by your computer, mobile phone, or other access device. This information includes:
– your IP address;
– device information including, but not limited to, identifier, name, and type of operating system; and
– standard web information, such as your browser type and the pages you access on our Websites.
2.2 As it is in our legitimate interests to process your data to provide effective services and useful content to you we collect this information in order to:
– personalise the Websites to ensure content from the Websites is presented in the most effective manner for you and your device;
– monitor and analyse trends, usage and activity in connection with the Websites to improve the Websites;
– Administer the Websites, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis; or
– keep the Websites safe and secure.
3. How do we share your personal data?
3.1 We will not disclose your personal information to anyone outside of DAG except in the circumstances set out in this policy.
3.2 We may allow our subcontractors or other providers acting on our behalf, including website hosts and email client providers, to access and use your personal information for the purposes for which you have provided it to us. If we do this, we will not give those individuals or organisations any rights to use your personal information (or to contact you) except in accordance with our instructions and this policy.
3.3 The only times we will pass your details to anyone else would be:
– where we are required to do so by any law or court order;
– where you have given us consent to do so; or
– where DAG or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets.
4. Where do we store your personal data?
4.1 The information that we collect from you will be transferred to, and stored at/processed in the Netherlands. Your personal data is also processed by staff operating outside the EEA who work for us or for one of our providers. Such staff are engaged in the implementation and support of DAG project activities. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
5. The security of your personal data
5.1 We have security measures in place to protect the loss, misuse and alteration of the information under our control.
5.2 Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Websites or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.
5.3 We will, from time to time, host links to and from the websites of our affiliates or third parties (including social media sites). If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
6. How long do we store your personal data?
6.1 We keep your information for as long as is necessary and is permitted or required by law.
7. Your rights
7.1 You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and with whom we share it. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.
7.2 Where you request access to personal data we hold about you, we will respond within one month of receipt of the request. However, we may take a further two months where the request is large or complex. We may charge a reasonable fee for the administrative costs of complying with the request. We may also request additional information to confirm your identification. If your request is manifestly unfounded or excessive, we may refuse to comply.
7.3 In certain circumstances, you have the right to ask us to delete the personal data we hold about you:
– where you believe that it is no longer necessary for us to hold your personal data;
– where we are processing your personal data on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; and
– where you believe the personal data we hold about you is being unlawfully processed by us.
7.4 To exercise any of these rights above, please contact our Data Protection Officer at email@example.com. In addition, you have the right to complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or other applicable data protection supervisory authority.
7.5 Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.
8. Withdrawal of Consent
8.1 Where you have provided your consent for us to process your personal data, you can withdraw your consent at any time by contacting our Data Protection Officer at firstname.lastname@example.org.
9.1 In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the Dutch Data Protection Authority or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.
10.1 Any changes we make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.
1. What are cookies?
3. Third party websites and social networks
3.2 Some of the content on our Websites is provided by third parties. This includes but is not limited to: Vimeo for hosted video. When you visit a page containing content from one of these sites a cookie may be set. We do not have any control over these cookies and they will be set pursuant to the third party’s own policy on privacy and cookies.
4. Disabling cookies