Privacy Policy

We want all our members, course providers, and supporters to feel confident and comfortable with how any personal information you share with us will be looked after or used. This Privacy Policy sets out how we collect, use, and store your personal information (this means any information that identifies or could identify you). This Privacy Policy may change so please remember to check back from time to time, this is version 4.0 and was last updated on the 01 November 2023. Where we have made any changes to this Privacy Policy, we will make this clear on our website or contact you about any changes.

1. Who we are

WICE is committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.

We are a "data controller" for the purposes of the EU General Data Protection Regulation 2016/679 ("Data Protection Law"). This means that we are responsible for, and control the processing of, your personal information.

For further information about our privacy practices, please contact WICE by writing to WICE, Boîte 275, 141 Avenue Félix Faure, 75015, Paris or emailing, dataprotection@wice-paris.org.

2. How we collect information about you

We collect information when you interact with us directly or via our website. For example, when you register for an event, become a member, donate, apply for a volunteer opportunity or any scenario where you provide us with your personal information.

WICE collects:

1. When visiting our website, information about your computer and about your visits to and use of this website (geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. We do not track IP addresses);
2. Information that you provide when completing your profile on our website, including your contact details and demographic information;
3. Information that you provide to us when subscribing to our email notifications and/or newsletters, including your name and email address;
4. Information relating to any purchases you make of our services or any other transactions that you enter through our website, including your name, address, telephone number and email address; We do not store credit card or bank account details.
5. Information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
6. Information contained in or relating to any communications that you send to us or send through our website, including the communication content and metadata associated with the communication. Information about the communications we send to you including the emails you open and the links that you click;
7. Information you send to us through our website and Social Media feeds whilst applying for any a volunteer role or position at WICE.

3. Information we collect and why we use it

Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone and mobile numbers and credit/debit card details (if you are making a purchase or donation), as well as information you provide in any communications between us. You will have given us this information whilst donating, joining as a member, registering for an event or course on our website or any of the other ways to interact with us.

We may use your personal information to:

1. Administer our website and business;
2. Enable your use of the services available on our website;
3. Supply services purchased through our website;
4. Send statements, invoices and payment reminders to you, and collect payments from you;
5. Send you non-marketing commercial communications;
6. Send you email notifications that you have specifically requested;
7. Send you our email newsletter, if you have requested it, you can inform us at any time if you no longer require the newsletter;
8. Send you marketing communications relating to our business which we think may be of interest to you, by email, you can inform us at any time if you no longer require marketing communications;
9. Deal with enquiries and complaints made by or about you relating to our website;
10. Keep our website secure and prevent fraud;
11. Verify compliance with the terms and conditions governing the use of our website.
12. If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
13. All our website financial transactions are handled through our payment services provider, PayPal. You can review the provider's privacy policy. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
14. To contact you about our events and courses and how you can support WICE (see section 8 on 'Marketing' below for further information).
15. To invite you to participate in surveys or research.

If you do not provide this information, we will not be able to process your donation, sign you up for an event, provide services you have requested, or effectively administer your membership, event attendance or the volunteering arrangement that you have entered into with us.

4. Legal basis for using your information

Under EU data protection law, we must have a valid basis for using your personal information and we may not collect store or use information other than as described in this policy. There are four ways we may have a valid basis for using your personal information:

1. Contract—Most of the information we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide details when you become a member or sign up for one of our events.
2. Consent—When you register and open an online account with us you will be invited to give us your consent to use your personal information as described in 'Agree to WICE's privacy policy. By opting in you are giving us your permission to process your data using consent as our legal basis. If you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time.
3. Legitimate Interests—We have a legitimate interest in using your personal information. If this is our reason for using your personal information, we must make sure that our interests do not override yours and you can object to this use of your personal information.
4. Legal Obligation—Lastly, we have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.

A full description of the different types of personal information we process, the purpose of the processing and the legal basis for the processing is shown below:

Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively.To create statistical information, market research, analysis and group profiles to better manage and run our organisation.

Our use of your data

1. To carry out our contract with you to provide you with membership services or allow you to attend one of our events.
2. To notify members and event attendees of any changes to our service.
3. To provide you with marketing information via email, post or other electronic means about goods and services we believe may be of interest to you.
4. To understand the effectiveness of the online advertising we show you and to deliver relevant advertising to you via our website.
5. To create statistical information, market research, analysis and group profiles to better manage and run our organisation.
6. To provide data to public authorities where legally required.

Legal basis for processing

1. Necessary for the performance of our contract with you or to take steps to enter into that contract.
2. Necessary for the performance of our contract with you or to take steps to enter into that contract.
3. You have given us your consent, or we rely on legitimate interest.
4. Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is relevant.
5. Our use of your data is necessary for our legitimate interests in ensuring that the service we provide to you is administered effectively.
6. We have a legal obligation to use your personal information where lawfully requested or required to do so by public authorities.

Our legitimate interests and your right to object

Legitimate Interests means the interests of our association in conducting and managing our courses, events and other services.

For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well.

When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing. If you wish to do so, please let us know by contacting dataprotection@wice-paris.org. Please bear in mind that if you object, this may affect our ability to carry out the tasks for your benefit.

5. Marketing

We will only contact you about our association, our aims and courses and events that we think you will be interested in. This could be by phone or email if you have agreed for us to contact you in this manner. If you have provided us with your postal address we may send you information about our work and how you can support WICE by mail unless you have told us that you would prefer not to hear from us in that way.

You can update your choices or stop us sending you these communications at any time by updating your member profile on the website www.wice-paris.org or contacting dataprotection@wice-paris.org.

Our marketing materials will take the following form to the following groups.

WICE DIRECT

This is our periodic newsletter, that will contain information on upcoming events and courses. Anyone can sign up by completing the form on the homepage. Members and those attending events can select to receive when they fill in the registration form.

Signing up via either way is taken as consent to send you the newsletter.

Members Messaging

If you are a member of WICE you will receive invitations to events and other information to help you get the most out of your membership.

You can unsubscribe from these communications by altering the options in your members page or clicking the unsubscribe page on the emails you receive.

You have given us your consent, or we rely on legitimate interest.

You will receive these communications up to 12 months after your membership expires.

Other Marketing

We may contact those who have attended courses or other events to let them know of other events that we think may interest them.

You have given us your consent, or we rely on legitimate interest.

You can unsubscribe from these emails in your members page or clicking on the unsubscribe in the emails you receive.

6. Sharing your Information

The personal information we collect about you will be used by our staff, course providers, and volunteers at WICE so that they can provide the best service to our members.

All these individuals will be required to agree to the WICE privacy guidelines so that we can ensure they understand the importance of protecting your data and have the knowledge to protect your personal data.

We may disclose your personal information:

1. To the extent that we are required to do so by law;
2. In connection with any ongoing or prospective legal proceedings;
3. To establish, exercise or defend our legal rights, including providing information to others for the purposes of fraud prevention and reducing credit risk;
4. To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
5. We do not, nor will we ever, sell or share your personal information with other organisations so that they can contact you for any marketing activities. Nor do we share any information about your web browsing activity.

7. Keeping your information safe

We take looking after your information very seriously. We've implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, processing, alteration, destruction, disclosure and loss.

Unfortunately, the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.

Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or web sites that have links on our site may collect personally identifiable information about you.

This privacy statement does not cover the information practices of those websites or advertisers.

Any debit or credit card details which we receive on our website are passed securely to PayPal our payment processing partner, according to the Payment Card Industry Security Standards.

8. How long we hold your information for

We only keep it as long as is reasonable and necessary for the relevant activity. For members and those attending event we will keep your data for 12 months after your membership expires or after you attend your last event. If you volunteer for a role we will store your information for no more than 3 months.

If you give us consent to be added to our mail list then, you will be left on the list unless you request that you are removed.

As already mentioned, we are legally obliged to maintain some financial and membership data. This includes, invoice data, which is name, product type, amount of currency, date and method of payment (but not card or account details). This will be kept for 10 years. Membership data, such as name, membership number, date joined.

9. Your rights

You have various rights in respect of the personal information we hold about you - these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting us at the address at the top of the page:

1. Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing (includes email) and provide us with evidence of your identity at the time of making any request.
2. Right to object: You can object to our processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
3. Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time. Please contact us as noted above, providing notice that you have withdrawn your consent.
4. Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you. Please contact us as noted above, providing details of the inaccurate or incomplete information, what is required to correct the inaccuracy or to complete the information we hold about you.
5. Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Please contact us as noted above, providing details of the personal information about you that you wish to have deleted.
6. Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred. Please contact us as noted above, providing details of your objection.
7. Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it. Please contact us as noted above, providing details of the information you wish to restrict.
8. No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making, however we wish to advise you of all your rights even if they are not presently relevant to the processing WICE carries out.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request. If we are unable to fulfil your request, then we will inform you as to the reason why.

If you feel that the data protection team is not complying with the law, or to find out more about our privacy policy, contact dataprotection@wice-paris.org. If you feel that WICE has an association has failed or is failing in complying with data protection law you have the right to complain to the French Data Protection agency CNIL www.cnil.fr and can make a complaint at their website here.

10. Monitoring

Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.