Last updated: 31 March 2019
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 www.silvertaskforce.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 The European Silver Task Force treats compliance with its privacy obligations seriously. This is why we have developed this Notice, which describes the standards that the European Silver Task Force applies to protect Personal Data.
1.4 For the purposes of this Notice, the European Silver Task Force located at Fieldfisher (Belgium) LLP, l'Arsenal Boulevard Louis Schmidtlaan 29 box 15, 1040 Brussels, Belgium and whose members are listed under the "About Us" tab ("the European Silver Task Force", "us", "we", or "our") acts as the data controller for the Personal Data that is collected via the Website. As a data controller, the European Silver Task Force 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 Koen Van Maldegem: koen.vanmaldegem@fieldfisher.com.
2. What Personal Data does the European Silver Task Force collect and why?
2.1 When you contact us, whether by telephone, by post or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep Personal Data associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
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.
Some of this information may be collected using cookies and similar tracking technology.
2.3 In general, we will use the Personal Data we collect from you only for the purposes described in this Notice or for purposes that we explain to you at the time we collect your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
3. Cookies
3.1 Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
3.2 Cookies can remain on your computer or mobile device for different periods of time. Some cookies are 'session cookies', which means they only exist when your browser is open and are automatically deleted when you close your browser or quit the app. Other cookies are 'persistent cookies', meaning they survive after your browser or app is closed and can be used by websites or apps to recognise your computer when you re-open your browser or app later. The length of the cookies used on our Website is explained in more detail below.
3.3 Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
3.4 Our Website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. When you visit our Website, we may place the following cookies:
Essential website cookies: These cookies are strictly necessary to provide you with services available through our Website and to use some of its features.
Our Website uses the following essential cookies: Name: Crumb Purpose: Prevents cross-site forgery (CSRF) Duration: Session; Name: Test Purpose: Investigates if the browser supports cookies and prevents errors Duration: Session.
Analytics and performance cookies: Analytics cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customise our Website for you. Performance cookies are used to enhance the performance and functionality of our Website. Analytics and performance cookies are non-essential to use of the website. However, without these cookies, certain functionality (like videos) may become unavailable.
Our Website uses the following analytics and performance cookies: Name: ss_cid Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site Duration: 2 years; Name: ss_cookieAllowed Purpose: Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies Duration: 30 days; Name: ss_cpvisit Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site Duration: 2 years; Name: ss_cvisit Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site Duration: 30 minutes; Name: ss_cvr Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site Duration: 2 years: Name: ss_cvt Purpose: Identifies unique visitors and tracks a visitor’s sessions on a site Duration: 30 minutes.
3.5 When you first visit our Website, we ask you agree to our use of cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
3.6 If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our Website.
3.7 For more information about cookies, including explanation about how cookies are placed on your device, or how to manage and delete them, visit http://www.allaboutcookies.org.
4. Who does the European Silver Task Force share your Personal Data with?
4.1 We may disclose your Personal Data to the following categories of recipients:
(a) to our European Task Force Members for purposes consistent with this Notice. We take precautions to allow access to Personal Data only to those staff 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.
5. How we protect your privacy
5.1 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 European Silver Task Force 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 European Silver Task Force. 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).
Specifically, our servers are located in the United Kingdom (UK). We have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Data between our group companies, which require all group companies to protect Personal Data they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided on request.
(a) Data Retention: We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
6. Your data protection rights
6.1 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 details: BrusselsInfo@fieldfisher.com.
(b) In addition, in certain circumstances, as stipulated in the applicable data protection legislation, you can object to processing of your Personal Data, 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 BrusselsInfo@fieldfisher.com.
(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) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided above.
(e) 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. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)
6.2 We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
7. Linking to other websites
7.1 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.
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.