This FACT® privacy notice (“Privacy Notice”) describes how the Federation Against Copyright Theft and FACT Worldwide (“FACT”, “we” or “us”) collects, uses, shares, and retains personal information that you provide to us, or that we collect, when you use the FACT website located at www.fact-uk.org.uk
Please note that if you disagree with anything in this Privacy Notice, you must not provide personal information to us in connection with FACT’s services.
1. Data Protection Contacts
FACT is located in Twickenham, Middlesex . You may contact FACT’s internal data protection resource if you have any questions or concerns about FACT’s policies or practices regarding Personal Data. The contact details are listed below:
Steven Parry, FACT, Regal House, 70 London Road Twickenham, TW1 3QS
2. Collection of Personal Information
Information You Directly and Voluntarily Provide to Us
Membership and/or Certification and/or Clients: If you provide your Personal Data to FACT to become a member and/or client and/or be certified you will be required to provide certain information as part of the registration process. This information may include your first and last name, email address, and business address. We may also request that you voluntarily provide other information, such as your phone number and information about your company as it relates to FACT’s products and services. Membership, Certification and Client information is used to communicate with you, to design content and activities that we believe would be of interest, and to ensure that FACT will not violate any UK law in providing you access to FACT’s services. If you wish to opt-out of receiving communications please inform us by email.
Events and Conferences: FACT may host events that include in-person and virtual conferences, training, knowledge sharing and webinars. If you register for one of our events we will collect your first and last name, email address, business or home address, information about the type of business you work for or with and your role in that business, which we will use to provide you with information and services associated with the event.
Certification Status: If you hold a FACT certification, we may share your certification status with third parties that ask about your status and we publish a current list of companies who are certified that is available to the public.
Communication with FACT: If you communicate or correspond with us by email, postal mail, telephone or other forms of communication, we may collect the information you provide. For example, if you correspond with us through email, we may collect and store your email address to send you any applicable correspondence such as a response to your enquiry, notification of FACT events, publications or other services, maintenance of a record of your complaint, and similar purposes.
3. Use, Sharing and Retention of Personal Information
A. How We Use Your Information
FACT uses personal information for the purposes described at the time of collection to provide services and products. FACT also uses your information, as permitted by law, to provide you with information about FACT, our services or other products and services in which we believe you may be interested. We may email you about services that we believe may be of interest to you. If you wish to opt-out of receiving these emails from us, please email email@example.com and put “OPT OUT” in the subject header. This will stop you receiving these types of email communications from us.
B. How We Share Your Information with Third Parties.
Except as set forth in this Privacy Notice, or when specifically agreed to by you, we will not disclose personal information we gather from you to third parties unless FACT is required to share this information to complete your request or for legitimate business purposes. FACT shares personal information in the following circumstances:
Third-Party Service Providers
We may share your information with vendors or third parties who deliver or provide goods and services or otherwise act on behalf of or at the direction of FACT. These third parties may include, for example, our third-party technology providers. These third-party service providers will only have access to the information needed to perform these limited functions on our behalf.
Response to Court Orders, Government Requests or to Protect Rights and to Comply with Our Policies
To the extent permitted by law, we will disclose your information to government authorities or third parties if: (a) required to do so by law or regulation, or in response to a subpoena or court order or any other enforceable governmental request or order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
Business Transfers; Bankruptcy
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. Unless you are residing in the European Economic Area (EEA), we reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users to third parties. FACT will still ensure the confidentiality and security of any user information. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Notice.
We may share your information with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
Where we do share your personal data with third parties, FACT takes steps to ensure that they use appropriate safeguards to protect your personal data.
C. Information for Individuals Located in the European Union.
Legal Basis for The Processing of Personal Information from EEA Residents
If you reside within the EEA, our processing of your personal information will be legitimised as follows:
(i) Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.
(ii) If the processing of your personal data is necessary for the performance of a contract between you and FACT or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b).”). If this data is not processed, FACT will not be able to execute the contract with you.
(iii) Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), for example complying in the fields of employment law.
(iv) And where the processing is necessary for the purposes of FACT’s legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud.
(v) You may also receive personalised advertising where you indicate to FACT specific interests by requesting information about a product or service.
4. EU Data Subject Rights
The EU GDPR and other countries’ privacy laws provide certain rights for data subjects (these are persons who can be identified).
This Privacy Notice is intended to provide you with information about what personal data FACT collects about you and how it is used.
If you wish to confirm that FACT is processing your personal data, or to have access to the personal data FACT may have about you, or have other questions, please contact us at firstname.lastname@example.org
You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside FACT might have received the data from FACT; what the source of the information was (if you did not provide it directly to FACT); where the personal data is stored and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by FACT if it is inaccurate. You may request that FACT erase that data or cease processing it, subject to certain exceptions. You may also ask FACT for your personal data to be supplemented or updated, or for its transformation into anonymous format or to block any data held in violation of the law, as well as to oppose its treatment for any and all legitimate reasons. You may withdraw your consent for the processing of personal data or the further processing of personal data by FACT at any time. You may also request that FACT ceases using your data for direct marketing purposes by emailing email@example.com
In many countries (including EEA countries), you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how FACT processes your personal data. When technically feasible, FACT will—at your request—provide your personal data to you or transmit it directly to another controller. You have the right to receive your personal information in a structured and standard format.
In addition to the information contained in this Privacy Notice, you may be provided with additional and contextual information concerning particular services or the collection and processing of your personal data upon request.
Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, FACT will provide you with a date when the information will be provided. If for some reason access is denied, FACT will provide an explanation as to why access has been denied.
5. Security of Your Information
FACT uses reasonable physical, technical and administrative measures to safeguard personal information you provide through the website or in connection with FACT’s products and services. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, FACT cannot guarantee or warrant the security of any information you transmit on or through the website and you do so at your own risk.
6. Data Storage and Retention
Your personal data is stored by FACT on its servers, and on the servers of the database management services FACT engages, located in the United Kingdom. FACT retains data for the duration of the client, member or certified business relationship with FACT and otherwise as required under applicable law. Personal data will be kept for no longer than is necessary for the purposes for which your personal data is processed. We will retain your personal data as long as you are a FACT member or client or require our services so that we can provide these services to you.
If you are located in the EEA, at the moment you cancel your FACT membership or terminate your business relationship with FACT or withdraw your consent for the processing of your personal information, all your personal data received and stored is erased if no longer needed by us. The only exception is if we are required to retain this personal data by law or to comply with our regulatory obligations. In such a case, we will only keep this personal data for as long as necessary. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact our data privacy contact at firstname.lastname@example.org
7. How to Contact FACT and Modify Your Information or Preferences
Questions regarding this Privacy Notice should be directed to FACT’s data privacy contact: email@example.com
If you would like to modify the types of marketing email messages you receive from FACT, you may do so by following the instructions within the body of any email message that you receive from us.
8. Modifications to this Privacy Notice
From time to time, FACT may need to update or modify this Privacy Notice to reflect changes in our business practices, data collection practices or organisation. We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on the website. It is strongly recommended to check the website often, referring to the date of the last modification listed. We will in any case not reduce your rights under this Privacy Notice without your explicit and informed consent. If you do not agree to the changes, you should discontinue your use of the website, and cease providing personal information to us, prior to the time the modified Privacy Notice takes effect. If you continue using the website or provide personal information after the modified Privacy Notice takes effect, you will be bound by the modified Privacy Notice
|Version||Date||Alteration||Next Review||Approved By||Author|
|1.01||April 29th||Released||April 18th 2019||Steven Parry|