Tourism Authority Of Thailand

Privacy Notice

This Privacy Notice (“Privacy Notice”) applies to users of the Tourism Authority of Thailand’s website at www.thecoloursofthailand.com (“Site”) and any of the services we offer (“Services”). We respect the privacy of every person who visits our Site or our visitor centre or who uses our Services, and we are committed to ensuring a safe online experience for all.

1. Purpose of this privacy notice

This Privacy Notice explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.

When we talk about “personal information”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them; such as, their physical appearance.

This Privacy Notice informs you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. It should be read in conjunction with our Terms of Use and our Cookies Policy.

This Privacy Notice only applies to the use of your personal information obtained by us, whether from you directly or from a third party. It does not apply to personal information collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

We care about your personal privacy. This policy regulates how we collect, use and protect data about you and how you can exercise your rights. Please contact us if you have any questions or comments regarding this Privacy Notice.

With reference to law, we refer below to the General Data Protection Regulation (GDPR) and other applicable Swedish data protection legislation.

2. About us

The Site and our Services are made available by the Tourism Authority of Thailand (“TAT”, “we”, “us, “our”). TAT is the data controller responsible for your personal information.

Tourism Authority of Thailand (TAT), founded in 1960, was the first organization in Thailand with a special responsibility to promote tourism in the country. The TAT Stockholm Office was established in 2002 and is responsible for the Nordic and Baltic countries. The TAT Stockholm Office provides travel information to the public, travel agencies and media and also works to encourage residents in the Nordic and Baltic countries to travel to Thailand. Read more at www.tourismthailand.org

3. How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us using the following contact details:

  • Send us an email to: info@tourismthailand.se
  • Call us on: +46 87 00 56 91
  • Write to us at: Tourism Authority of Thailand
    Drottninggatan 33 GF, 111 51 Stockholm, Sweden

4. How we collect and receive personal information

We collect and receive personal informationusing different methods:

  • Personal information you provide to us.

You may give us your personal information directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site or in our visitor centre, subscribe to receive our marketing communications or provide feedback to us.

  • Personal information we collect from you automatically.

When you access and use our Site, we will automatically collect certain technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies (see the “Our Use of Cookies and Similar Technologies” section below).

  • Personal information received from third parties.

From time to time, we will receive personal information about you from third parties. Such third parties may include analytics providers, payment providers, hotel and transport providers and third parties that provide technical services to us so that we can operate our Site and provide our Services.

5. We collect personal information about

We collect and process personal informationfrom the following people:

  • Site visitors.

If you browse our Site, register as a member on our Site, contact us with an enquiry through our Site, submit a complaint through our Site or use any Services available on our Site, we will collect and process your personal information in connection with your interaction with us and our Site.

  • Visitors to our visitor centre.

If you attend one of our visitor centres, we will process personal information about you which you may volunteer in connection with the purpose of your visit and any enquiries you may have. For example, you may volunteer information about yourself when asking us to assist you in finding accommodation or transportation suitable for your needs.  

  • Event attendees.

If you attend one of our events, we will process personal information about you in connection with your attendance at the event. For example, we may ask you to complete a survey, feedback form or other document relating to the event.

  • Suppliers (including subcontractors).

If you supply products or services to us on your own behalf, we will collect and process your personal information in connection with our receipt of products and services from you and, where relevant, our provision of our Services to others. This may include personal information included in any email or telephone communications or recorded on any document relating to an order of products or the provision of services.

  • Individuals who work for our partners and suppliers.

Corporate entities and other organisations are not data subjects, although any individuals who work for them are. If you work for or otherwise represent an organisation which is one of our partners or suppliers and you are engaging with us on behalf of that organisation, whether through our Site or otherwise, we will collect and process your personal information in connection with our receipt or provision of products and services and our wider relationship with your organisation.

  • Job applicants.

If you apply for a job with TAT (whether in Thailand or anywhere else we operate), whether through the Site or otherwise, we will collect and process your personal information in connection with your application.

6. Personal information we collect and how we use it

Our primary reasons for collecting personal information from you is to: (i) promote tourism in Thailand and to provide services in connection with this purpose; (ii) verify your identity (where applicable); (iii) help us improve our Site and our Services and develop and market new products and services; (iv) carry out requests made on our Site; (v) investigate or settle enquiries or disputes; (vi) comply with the applicable law, court order, other judicial processes and the requirements of regulators; (vii) enforce our agreements with you; (viii) protect the rights, property and safety of us or third parties, including users of our Site and Services; (ix) provide support for the provision of our Services; (x) carry out recruitment activities, and (xi) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

  • Fulfilment of our Services.

Use of our Site, our visitor centre and our Services

We collect and maintain personal information that you submit to us during your use of our Site, our visitor centre and the Services we offer on our Site or through our visitor centre. We may collect and process your personal information whether you are interacting with us on your own behalf or on behalf of any organisation you represent.

The personal information we process may include your name and contact information (such as email address, postal address and telephone number) and your payment information (where applicable). We process this information so that we can fulfil the supply of Services you have requested from us, maintain our user databases and to keep a record of how our Services are being used. If you attend our visitor centre, we will process personal information about you which you volunteer in connection with the purpose of your visit and any enquiries you may have. Some Services we offer are also subject to separate terms and conditions which will apply to your use of such Services.

If you click on one of the social media links on our Site, or otherwise interact with our social media accounts, such as on Facebook or Instagram, we may receive information relating to such interaction and to your own social media accounts. 

We also have security measures in place at all our visitor centres, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need-to-know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft). We may require visitors to our visitor centre to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).

Registering and accessing your member’s account on our Site

The main TAT website allows Site visitors to register a member’s account with us in order to gain access to additional features of the Site and exclusive member offers from us. We will ask all prospective applicants to complete the registration form, providing a username, email address and password as well as [other personal details] and information about any forthcoming trips and travel preferences.

We will use your personal information in order to process your application for a member’s account. Once you are registered, we will process your username and password to identify you when you log into your account and the secure areas of our Site. We will also process your login information so that we can administer your account with us and contact you about your account.

Your access to and use of our Site, including any secure member’s area, is subject at all times to our Terms of Use.

Photo requests on TAT News

Our TAT news microsite features a “Photo Request” function, which allows accredited members of the online and traditional media as well as freelance writers to request access to our collection of high resolution images of Thailand’s tourist attractions, activities and infrastructure. If you request an image from us, we will ask you to complete the request form, providing your name, job title, the name of your organisation (if applicable), your email address, your postal address, mobile and landline telephone number, and any other information relevant to your request. We will process this information in order to process and respond to your request.

Your contributionsto TAT News

If you write an article or blog for us or contribute in any other way to publications we send to our members and/or publish on our Site or in print, we may use your personal information (such as your name and the name of your organisation) to credit you for your contribution. If you provide photographs or other images in support of your article or blog, we may publish one or more of those images alongside your article or blog.

Attending TAT events

From time to time, we may organise and host Trade and other events for the purpose of promoting Thailand as a tourist destination. We may process your name and contact information (including email address, postal address and telephone number) to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.

If you attend one of our events, we may use your personal information to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications we send to our members and/or publish on our Site or in print.

Our legal basis for processing

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services requested by you and others in an effective and efficient way.

If we specifically ask your permission to use your photographs, quotes, testimonials or other content, then our processing of such personal information will be based on consent.

  • General enquiries.

Our Site features a “Contact Us” page which invites you to submit general enquiries about our Site, our organisation and our Services by email or via a “live chat” function. We also accept enquiries by email, telephone, fax and post using the contact details available in the “How to Contact Us” section above.

When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number), the name of your organisation and any personal information you volunteer that is relevant to your enquiry. We use this information to manage and respond to your enquiries and requests. Your personal information will also, where applicable, be shared with the third party hotel or other business to which your enquiry relates to enable the relevant third party to assist with your enquiry. Please see the “Sharing Personal Information” section below for more information about how we share your personal information.

Our legal basis for processing

It is in our legitimate interest to use your personal information in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you.

  • Prize draws, prize competitions and other promotions.

From time to time, we may run prize draws, prize competitions and other promotions on our Site and/or on our social media accounts. For the purposes of administering such promotions, we may process your name, contact details (including email address, postal address and/or telephone number), social media handle (if relevant), payment details (if relevant) and any other personal information volunteered by you in your promotion entry. Our promotions may be subject to separate terms and conditions which you may be required to accept as a condition of entry.

Our legal basis for processing

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the promotion to which you may be asked to agree as a condition of entry) or it is in our legitimate interest to use your personal information to enable you to participate in any prize draws, prize competitions and other promotions.

  • Insight and analysis.

We analyse your contact details with other personal information that we observe about you from your interactions with our Site, [our email communications] and/or with our Services.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site; and
  • information regarding your personal or professional interests, demographics, experiences with our Services and contact preferences.

Our web pages [and emails] may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to count users who have visited a web page [or opened an email] and collect other types of aggregated information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to [the source email] and/or the relevant Tag.

[In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.]

Please see our Cookies Policy for further information.

This information is used to create insights about our visitors’ browsing habits on our Site. Where we have your consent to do so, we will also use your location data for insight and analysis purposes. 

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see.

We use this information to help us with the selection of future product and service lines and website design and to remember your preferences.

We also use this information for marketing purposes (see the “Marketing Activities” section below for further details).

Our legal basis for processing

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookies Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide good quality services to you and others.

We will only use your location data for insight and analysis purposes where we have your consent to do so.

Marketing activities.

  • Postal marketing.

We use your name and postal address to send you (or the organisation you represent) marketing communications by post. Our postal marketing communications will include press releases and information promoting Thailand as a tourist destination, as well as general information about our organisation, our Site, our visitor centre, the Services we provide and the events and promotions we offer from time to time.

Our postal marketing will include personalised and non-personalised postal marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised postal marketing will feature services, events, offers and/or promotions that we think are most likely to appeal to you. Non-personalised marketing is marketing about our services, events, offers and/or promotions generally and is not tailored to any particular individual. 

Where we are sending you personalised postal marketing, we also use information that we observe about you from your interactions with our Site, [with our email communications to you,] with our visitor centre and/or with our Services in order to decide what sort of personalised marketing communications to send you. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected.

Our legal basis for processing

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookies Policy for further details.

Where your personal information is not in an anonymous form (for example, your postal address), it is in our legitimate interest to use your personal information for postal marketing purposes.

  • Email and SMS/MMS marketing.

We use your name and email address to send you (or the organisation you represent) marketing communications by email. We use your mobile telephone number to send you marketing communications by SMS/MMS. Our email and SMS/MMS marketing communications will include press releases and information promoting Thailand as a tourist destination, as well as general information about our organisation, our Site, our visitor centre, the Services we provide and the events and promotions we offer from time to time. Members can also subscribe to receive special deal alerts by email.

Our email and SMS/MMS marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature services, events, offers and/or promotions that we think are most likely to appeal to you. Non-personalised marketing is marketing about our services, events, offers and/or promotions generally and is not tailored to any particular individual. 

Where we are sending you personalised email or SMS/MMS marketing, we also use information that we observe about you from your interactions with our Site, [with our email communications to you,] with our visitor centre and/or with our Services in order to decide what sort of personalised marketing communications to send you. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected.

Our legal basis for processing

We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.

  • Social media remarketing.

We use information that we observe about you from your interactions with our Site, [with our email communications to you] and/or with our Services to provide you with personalised advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected. We do this using Facebook Customer Audiences and/or Google Customer Match respectively. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

Our legal basis for processing

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookies Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us using your email address and sharing your email address in an encrypted format with Facebook and/or Google, respectively for marketing purposes.

  • Social media insight.

Where you are a registered user of Facebook or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services who share similar interests to you based on:

  • information that we observe about you from your interactions with our Sites, [with our email communications to you] and/or with our Services (see the “Insight and Analysis” section above for more details of the information collected and how it is collected); and
  • the information Facebook and/or Google hold about you.

We do this using Facebook Lookalike Audiences and/or Google Similar Audiences, respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

Our legal basis for processing

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookies Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

  • Recruitment.

We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

The personal information we process may include your name and contact information (including your email address, postal address and telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae and covering letter, which you volunteer in an application form or during an interview or which is contained in any reference we receive about you. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Our legal basis for processing

Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions.

We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

  • Receipt of services from suppliers.

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.

The personal information we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal information you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or the organisation you represent or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to provide our Services to you and others in an effective way.

  • Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • to protect the rights of third parties; and
  • in connection with a business transition; such as, a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets. 

Our legal basis for processing

Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.

7. If you fail to provide your personal information

Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that personal information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal information we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

8. How we obtain your consent

Where our use of your personal information requires consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us using the contact details set out in the “How to Contact Us” section above.

9. Our use of cookies and similar technologies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookies Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

10. Third-party links and services

Our Site contains links to third party websites and services. When you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies.

Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. For example, our website invites you to connect with us on social media platforms; such as, Facebook and Instagram. When you click on the links we provide to such platforms, you will be transferred from our Site to the relevant platform and the privacy notice (and other terms and conditions) of that platform will apply to you.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal information collected by us through our Site, the supply of our Services and/or in connection with our business operations and does not apply to these third party websites and third party service providers.

11. Sharing personal information

We will only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations.

When processing your personal information, we may need to share it with third parties as follows:

Third-party organisations that provide applications/functionality, data processing or IT services: We share personal information with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal information may be stored in any one of them. We also share your personal information with third-party service providers to assist us with insight analytics. These providers are described in our Cookies Policy.

Hotel and transport operators and other travel-related businesses: When you submit an enquiry to us about a hotel or transport provider, we will share your enquiry (including any personal information you volunteer) with that third party so that they can provide the information and assistance that you have requested.

Payment providers and banks: We share personal information with third parties who assist us with the processing of payments and refunds.

Event partners and suppliers: When we run events, we will share your personal information with third-party services providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal information with such organisations for use in relation to the event.

Third-party email marketing and CRM specialists: We share personal information with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications.

Suppliers of postal and courier services: We share personal information with suppliers who assist us in sending out our postal marketing communications and membership-related communications.

Third-party organisations that assist us with the administration of our promotions: We share personal information with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.

Recruitment agencies and related organisations: We share personal information with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.

Auditors, lawyers, accountants and other professional advisers: We share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies: We share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate our Site and our visitor centres and to provide our Services.

12. Transfers outside the European Economic Area (“EEA”)

When you submit personal information to us, whether through your interactions with our Site, our international visitor centres and branch offices or our headquarters in Thailand, you acknowledge that your personal information will be transferred outside the EEA to Thailand where it will be stored and processed by us and our suppliers for the purposes set out in this Privacy Notice.

Where necessary in order to operate our Site and our visitor centre and to otherwise deliver our Services, we will transfer personal information to countries outside the EEA.

Non-EEA countries do not have the same data protection laws as the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal information, may not give you the same rights in relation to your personal information and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal information.However, when transferring your personal information outside the EEA, we will comply with our legal and regulatory obligations in relation to your personal information, including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

We will take reasonable steps to ensure the security of your personal information in accordance with applicable data protection laws.

When transferring your personal information outside the EEA, we will ensure that we have a lawful basis for the transfer. Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your personal information outside the EEA at the time you provide your information) or one of the following safeguards:

Adequacy decisions: We may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Model clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

EU-U.S. Privacy Shield: Where we have partners or suppliers based in the US, we may transfer personal information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.

Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the EEA.

13. How long we keep your personal information

Regarding personal information we have processed in connection with the supply of our Services, we will retain personal information relevant to that supply of Services for six (6) years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we will retain relevant personal information for three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

14. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Site and our Services.

15. Personal information of children

We do not specifically target our Site and our products and services at children. However, due to the nature of our organisation and the products and services we provide, we may from time to time collect and process personal information relating to individuals under the age of 16. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal information of children. However, if you are under the age of 16, you must ask a parent or guardian for permission before using our Site and our products and services. If you are a parent, please ensure that you supervise your child’s use of our Site and our products and services.

16. How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:

  • Your right of access.

If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

  • Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

  • Your right to restrict processing.

You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly. 

  • Your right to data portability.

You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

  • Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for the purposes direct marketing.
  • Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

  • Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.  

  • Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

17. Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.

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