This General Privacy Policy (the “Policy”) applies to all present and future members of Invest Europe AISBL (“Invest Europe”) and all present and future attendees of Invest Europe’s events, including courses given in the framework of Invest Europe Training. In addition, this Policy also applies to the processing carried out by Invest Europe in the context of its communications, research and public affairs activities as well as its processing of any information relating to representatives of associations, companies or other partners cooperating with or providing services to Invest Europe. Please make sure you communicate it and make it available to all your employees and other representatives, where relevant.
The purpose of the Policy is to describe (a) the conditions under which Invest Europe, as controller (i.e. the legal entity that decides on the purposes and means of personal data processing) processes personal data (i.e. data relating to an identified or identifiable individual, such as yourself and your relevant employees and other representatives) and (b) your rights and our obligations in relation to such processing.
Until 24 May 2018, the above processing is subject to the Belgian Law of 8 December 1992 on the protection of privacy with regard to the processing of personal data, as modified by the law of 11 December 1998 transposing Directive 95/46/EC.
As from 25 May 2018, the above processing shall be subject to EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”).
In general, Invest Europe collects general identification information about all individuals with whom Invest Europe interacts, such as the name, title, position, company name, professional and/or private email and/or postal address, fixed and/or mobile phone number as well as any information provided directly by such persons (e.g. by email or through providing business cards).
In addition, Invest Europe collects the following information about the specific categories of individuals listed below.
If you are a member of Invest Europe or an attendee at an event or meeting organised by Invest Europe, Invest Europe will collect the following categories of personal data relating to you, as part of its activities:
Invest Europe may also process so-called sensitive personal data about yourself (i.e. your dietary requirements which may infer health-related and/or religious data).
If you are an official, a policy maker or an assistant to an official or a policy maker, Invest Europe may collect the following categories of personal data relating to you, most of which being publicly available on the websites of the institutions in which you are involved, in the framework of its public affairs activities:
If you are a journalist, Invest Europe collects from its media database provider, currently Gorkana, the following categories of personal data relating to you, in the framework of its communications activities:
If you are a representative of associations, companies or other partners cooperating with or providing services to Invest Europe, Invest Europe collects the following categories of personal data relating to you in the framework of such cooperation:
If you are a fund manager, a representative of a company involved in the private equity and venture capital industry (whether you or your company is a member of Invest Europe or not) or if you are an individual who wants to submit a request for specific research through Invest Europe’s research helpdesk, Invest Europe collects the following categories of personal data relating to you:
Such processing shall be made in compliance with applicable data protection law and include the information you voluntarily provide when answering questions in our registration forms or otherwise as well as any information we receive from third parties.
If you provide Invest Europe with the personal data of another person belonging to any of the categories of individuals listed in this Section 1, you acknowledge having informed this person beforehand of this General Privacy Policy and, where required, having obtained the consent of this person for this communication.
Invest Europe only handles personal data relating to you as a member (present and future) for specific purposes, based on your consent or our legitimate interest, which is to manage the relationship with you, and in particular for:
Invest Europe only handles personal data relating to present and future attendees of events and courses provided in the framework of the Training for specific purposes based on your consent or our legitimate interest, and in particular for:
Invest Europe only handles personal data relating to officials, policy makers and their assistants for specific purposes based on its legitimate interest, which is to participate in the policy debate regarding private equity and venture capital in Europe, and in particular for:
Invest Europe only handles personal data relating to journalists for specific purposes based on its legitimate interest, which is to participate in the policy debate regarding private equity and venture capital actors in Europe, to improve the reputation and understanding of the private equity industry and to promote European private equity to global investors, and in particular:
Invest Europe handles personal data relating to representatives of associations, companies and other partners cooperating with or providing services to Invest Europe for the following purpose based on Invest Europe’s legitimate interest, which is to communicate with contact persons in cooperating associations, companies and other partners: for communications with respect to such cooperation and provision of services.
Invest Europe handles personal data relating to (i) fund managers, (ii) representatives of companies involved in the private equity and venture capital industry or (iii) individuals who submitted requests for specific research through Invest Europe’s helpdesk, for specific purposes based, as the case may be, on the consent of the data subjects or on Invest Europe’s legitimate interests (i.e. to carry out research regarding private equity and venture capital in Europe, improve the reputation and understanding of the private equity industry) and, in particular, for:
More generally, Invest Europe processes personal data of contacts on the basis of its legitimate interest, which is to communicate with relevant stakeholders about its core activities in relation to the private equity and venture capital sector, or on the basis of its legal obligations, for the following purposes:
Taking into account the state of the art of the technology, the costs of its implementation and the nature of the personal data it processes about you, Invest Europe has implemented appropriate technical and organisational measures to ensure a level of security and confidentiality to your personal data so as to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
Moreover, when handling your personal data, Invest Europe:
Invest Europe may disclose your personal data only to the following specific categories of recipients: our IT and personal assistance service providers, sponsors, other members, official and public bodies, and event organisers. Whenever required, such data may also have to be communicated to relevant public authorities in Belgium and abroad as they may so require in compliance with applicable law.
When you registered to an event including a course given in the framework of the Training organised by Invest Europe, you may have given your consent so that Invest Europe shares your contact details with the sponsors of the event and the other attendees, including attendees coming from countries outside the European Economic Area or “EEA” (i.e. the EU Member States plus Iceland, Liechtenstein and Norway) which do not necessarily offer an adequate level of personal data protection and therefore present certain risks in relation to the processing of, and access to, the personal data e.g. by local public authorities.
In the framework of the administration of our mobile networking application, Invest Europe transfers personal data relating to you to the supplier running the mobile networking application in the USA. For that purpose, Invest Europe has entered into the standard data protection clauses (controller to processor) adopted by the EU Commission (Decision 2010/87/EU) with the supplier of the mobile application.
If you are an official, a policy maker or an assistant to an official or a policy maker, Invest Europe may disclose your personal data to the following categories of recipients: our IT service providers, other associations having the same object as (or a similar one to) Invest Europe (including associations located outside the EEA), as well as some official and public bodies. Where required to allow the transfer outside of the EEA, Invest Europe shall enter into the standard data protection clauses (controller to controller) adopted by the EU Commission (Decision 2004/915/EC) with the relevant recipients.
Whenever required, such data may also have to be communicated to relevant public authorities in Belgium and abroad as they may so require in compliance with applicable law.
If you are a journalist, Invest Europe may disclose your personal data to the following categories of recipients: our IT service providers email marketing services providers and consultants which may be located outside the EEA. Invest Europe has entered into standard data protection clauses (controller to processor) adopted by the EU Commission (Decision 2010/87/EU), when required, with the above categories of recipients. Whenever required, such data have to be communicated to relevant public authorities in Belgium and abroad as they may so require in compliance with applicable law.
If you are a representative of associations, companies or other partners cooperating with or providing services to Invest Europe, Invest Europe may disclose your personal data to the following categories of recipients: our IT service providers.
If you are a fund manager, a representative of a company involved in the private equity and venture capital business who agreed to provide information for research purposes or if you are an individual who submitted a request for specific research through Invest Europe’s helpdesk, Invest Europe may disclose your personal data to the following categories of recipients: our IT service providers and other national venture capital associations. If this is the case, Invest Europe will make sure that appropriate safeguards are in place with such recipients to protect your personal data and their confidentiality.
You may exercise the following rights with respect to your personal data under the conditions and within the limits set forth in the applicable data protection law:
If the processing of personal data relating to you is based on your consent, you also have the right to withdraw it at any time, without affecting the lawfulness of our processing before such withdrawal.
If we transfer personal data relating to you outside of the EEA to a country which is not recognised as offering an adequate level of data protection by the European Commission, you may obtain a copy of the safeguards (such as the standard contractual clauses referred to in Section 4) we have put in place to enable such transfer in compliance with the data protection law.
You can exercise the above rights by either sending an email to Invest Europe at chiefexecutive@investeurope.eu or by sending a dated and signed letter addressed to The Chief Executive, Invest Europe, Place du Champ de Mars, B-1050, Brussels, Belgium. A scan or hard copy of your identity card or passport should be included for identification purposes.
If you are not satisfied with the way we process your personal data, please let us know and we will investigate your concern using the above communication means. You have also the right to make a complaint to the competent data protection authority.
Changes or additions to the processing of your personal data as described in this policy, such as other purposes for processing your personal data or new recipients of such data, may be notified to you through amendments to this policy or through individual notice.
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