Privacy & Cookies Policy

v1.4.5 - last updated 5/11/2018

Overview

In order for us to operate the CEFLEX initiative and provide our services to You, it is sometimes necessary for us to collect or process information about You. In general terms, this information will take one or more of the following forms:

  1. Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;
  2. Information that is automatically sent to us by Your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;
  3. Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.

This privacy policy sets out the detail of what information we collect, as well as how that data is used and protected.

Our commitment to data privacy

CEFLEX is committed to maintaining the trust and confidence of our stakeholders and other interested parties. In particular CEFLEX is not in the business of selling, renting or trading email lists with other companies and organisations for marketing purposes.

This Privacy Notice provides information about when and why we collect your personal information, how we use it and how we keep it secure.

CEFLEX is committed to maintaining the security of personal and respecting privacy rights. We pledge to handle your data fairly and legally, as well as being transparent about what data we collect about you and how it is used.

Who we are

Stichting CEFLEX is a not-for-profit initiative established in The Netherlands.

We, CEFLEX, act in the capacity of Data Controller, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:

Data Controller: Stichting CEFLEX

Address: Watermolen 6, Bergschenhoek, 2661LA, The Netherlands

Email correspondence: info@ceflex.eu.

Definition of ‘personal data’

When we refer to ‘personal data’ we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc. We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data.

Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not, generally, allow us to identify you directly. However, for completeness, we will cover the use of such data here also.

Who we share data with

We operate on a strict ‘need to know’ basis for all data that we work with, and that is particularly true for any personal data. The only people/organisations that are granted access to personal data are those who are directly involved in CEFLEX’s work, and the providers of the systems and technology that we use. They are:

  • Our web & email hosting providers (currently InterIP) who provide the physical server infrastructures that our website(s) operate on. InterIP servers are based in the European Union, and no customer data is transferred outside the European Economic Area
  • Our cloud storage and technology suppliers (currently Dropbox, Google & Amazon Web Services).
  • Employees of Blackbox Web Design who provide website design and/or support services, and therefore require access to our website systems.
  • Defiant Inc, the providers of the Wordfence™ security software that protects our website. Only limited, technical data (such as device IP address, browser type/version, language etc) are transmitted.
  • The Rocket Science Group LLC, providers of the Mailchimp® email campaign management system. Mailchimp uses servers based outside the European Economic Area. They are compliant with the EU-US Privacy Shield Framework.

We have agreed Terms of Service and/or Data Privacy Agreements with all of the 3rd party technology suppliers above which detail our respective responsibilities for data security.

In all cases where our 3rd party service providers have an establishment outside of the European Economic Area (EEA), we ensure adequate protection of personal data via the accepted EU Model Contract Clauses or EU-US Privacy Shield framework. We take these precautions to ensure that the companies to which we entrust personal data have the relevant technical and organisational measures in place.

How your data is protected

We take the security of all personal data very seriously, and that data is protected in a number of ways:

  • Access control: access to personal data is strictly limited in line with our policy detailed in the ‘who we share data with section’ on this page.
  • Physical & technical security of any external storage devices – data is not stored on removable media (such as USB drives) and any other storage devices, such as laptops, are physically secured when not in use, and protected by standard username/password credentials – where strong passwords are enforced and never shared.
  • Dedicated security software: We operate dedicated security scanning and access control software on our website. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
  • Data encryption: Our website is secured with SSL encryption, which means that all traffic to and from our servers is encrypted. This applies to our own administrative access to the website as well as that of users of our services.
  • Due Diligence in selection of third party service providers: we use a very limited number of third party service providers, but some are essential for the provision of physical hosting environments and cloud services. One of the core factors in the selection of such providers is their ability to provide secure systems and processes. We have written Data Processing Agreements with each of our core service providers that sets out the requirements for data security.

Access to your personal data

In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:

  • You have the right to obtain from us confirmation about whether any such data is being held;
  • You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
  • Even if you have consented to Us processing your personal data, you have the right to withdraw that permission at any time;
  • You have the right to require us to rectify any incomplete or incorrect information held about you;
  • You have the right to require us to erase the data held about you (the ‘right to be forgotten’);

In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):

  • You have the right to object to the legal basis upon which we are collecting this data, and We have an obligation to consider and respond to that objection;
  • You have the right to request the prevention of further processing of your data while your objection is considered;
  • You have the right to make a complaint to the relevant data protection authority
  • In most circumstances, you can exercise these rights without paying a fee to us.

What We Do With Your Data

What we do with your data depends on the relationship that we have with you.

Organisations that express an interest in the CEFLEX initiative

When individuals and organisations contact CEFLEX to enquire about the initiative or request membership as a stakeholder, is it necessary that we process the personal data provided to us in order to respond to that enquiry. In particular:

  • We will store the contact details that you provide to us (such as your name, email address, phone number, job role and company name)
  • We will use those contact details to respond to your enquiry and to gauge your interest in the CEFLEX initiative

Where practical, we will ask for your express consent to use your data in this way, but please note this is not the only legal basis on which we process the data. Primarily, we must process your personal data to enable us to respond to your enquiry, and it is in our legitimate interest to follow up on all expressions of interest in the CEFLEX initiative.

Organisations that become confirmed stakeholders in the CEFLEX initiative

Communication and collaboration with, and between stakeholders is a central part of the CEFLEX initiative, and it is therefore necessary for us to process personal data to fulfill this communication role. It is also in our legitimate interest to communicate with all stakeholders. In particular:

  • We will store the contact details that you provide to us (such as your name, email address, phone number, job role and company name)
  • We will use those contact details to send you email communications and updates on the programme, as well as other related information that we consider might be of genuine interest to you
  • We may share your contact details with other confirmed stakeholders within the CEFLEX initiative, to encourage further collaboration and participation in the initiativeand related workstreams
  • We will NOT share your personal details with any organisations outside the CEFLEX initiative for marketing or other purposes.

In some scenarios, we ask for your explicit consent to process your personal data in these ways, and you may withdraw your consent at any time by contacting us at info@ceflex.eu. Please note that your consent may not be the only lawful basis on which we process data.

Suppliers and potential technology providers

Communication and collaboration with, and between technology (and other) suppliers is a central part of the CEFLEX initiative, and it is therefore necessary for us to process personal data to fulfill this communication role. It is also in our legitimate interest to communicate with suppliers. In particular:

  • We will store the contact details that you provide to us (such as your name, email address, phone number, job role and company name)
  • We will use those contact details communicate with you about business opportunities or other related matters that we consider may be of relevance to you
  • We may share your contact details with any confirmed stakeholders within the CEFLEX initiative that we consider may be interested in the services that you provide
  • We will NOT share your personal details with any organisations outside the CEFLEX initiative for marketing or other purposes.

In some scenarios, we ask for your explicit consent to process your personal data in these ways, and you may withdraw your consent at any time by contacting us at info@ceflex.eu. Please note that your consent may not be the only lawful basis on which we process data.

Types of data collected

Website contact forms

When you complete one of the contact forms on our website, we will ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request.

If you do not use or submit an online form on the website, no data will be collected in that regard.

More Information

Legal Basis:

Consent (GDPR Art 6(1)(a)): Generally, we will ask for your explicit permission to process this data before you are able to submit the contact form. We will also give you a link to our Privacy Policy (this document) that you may review before submitting your details.

Types of processing

  • We will store the information you provide to us in our website database and in our secure cloud storage environment. Such storage allows us to efficiently access your data and respond to your requests;
  • For the purpose of maintaining the integrity of our systems, we may also store this data in system backups, which are encrypted and held securely by our technology partner Amazon Web Services;
  • We may use this information to contact you about other elements of the CEFLEX initiative that we believe may be of genuine interest to you;
  • We will NOT use this data for any further purpose without your express further consent;
  • We will NEVER sell your information to any 3rd party.

If you (or your organisation) becomes a confirmed stakeholder in the CEFLEX initiative, we may additionally process your personal data in the following ways:

  • We may add your contact details to our email mailing list for the purpose of sending you initiative and workstream updates. When we send emails via our mailing list we will always include a clear option for you to ‘unsubscribe’ from future mailings.
  • We may share your personal data with other confirmed CEFLEX stakeholders

Withdrawing your consent

Where you have provided your consent for us to process your personal data, you may withdraw that consent at any point, by contacting us at info@ceflex.eu.

Data minimisation:

We will only ask you for the minimum amount of information required to appropriately fulfil your request. This will usually be your name, one or more contact details, and any specific information about your request.

Retention

Unless you choose to become a confirmed stakeholder within the CEFLEX initiative, we will retain this data for a maximum of 12 months. If your organisation does become a confirmed stakeholder, we will retain the data for the length of our ongoing relationship plus a maximum of 12 months.

Face-to-Face and Direct Emails

If you volunteer personal information to us as part of a request for information, either by sending us an email, during a face-to-face meeting or call, or any other direct means, we will clearly need to process that information in order to respond to your request.

Similarly, if you provide contact information for other individuals within your organisation, it will be necessary for us to process their information.

More Information

Legal Basis:

Consent (GDPR Art 6(1)(a)): Generally, we will ask for your explicit permission to process this data in this way. We will refer you to our Privacy Policy (this document).

Contract (GDPR Art 6(1)(b)): In the case of responding to your email communications, it is essential for us to process that limited personal data (for example your name and email address) in order that we can respond to your request.

Legitimate Interest (GDPR Art6(1)(f)): Where you provide the contact details of other individuals within your organisation for the express purpose of involving them in the CEFLEX initiative, we consider that it is our legitimate interest to process that data.

Types of processing

  • We will store the information you provide to us in our secure cloud storage environment. Such storage allows us to efficiently access your data and respond to your requests;
  • We will store your name and email address in our email system to facilitate future communication
  • We will use this information to respond to your specific request for information
  • We may use this information to contact you about other elements of the CEFLEX initiative that we believe may be of genuine interest to you;
  • We will NOT use this data for any further purpose without your express further consent;
  • We will NEVER sell your information to any 3rd party.

Withdrawing your consent

Where you have provided your consent for us to process your personal data, you may withdraw that consent at any point, by contacting us at info@ceflex.eu.

Data minimisation:

We will only ask you for the minimum amount of information required to appropriately fulfil your request. This will usually be your name, one or more contact details, and any specific information about your request.

Retention

Unless you choose to become a confirmed stakeholder within the CEFLEX initiative, we will retain this data for a maximum of 12 months. If your organisation does become a confirmed stakeholder, we will retain the data for the length of our ongoing relationship plus a maximum of 12 months.

Technical data (such as ‘IP address’)

When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device, the browser type and version that you are using and your broad geographical location.

Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).

IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.

Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’, and accordingly we do not seek your consent to collect it.

More Information

Legal Basis

In the event that such anonymous data is considered to fall within the scope of the applicable data protection regulations, the legal basis for processing such data is:

Our Legitimate interest (GDPR Art 6(1)(f)): The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.

Types of processing

  • We will store the information you provide to us in our website server logs
  • For the purpose of maintaining the integrity of our systems, we may also store this data in infrastructure backups
  • We will NOT use this data to attempt to identify an individual person

Retention

Server logs are automatically rotated on our systems, and are retained for a maximum of 12 months following the closure of the relevant log file.

Cookies & ‘similar technologies’

Cookies (and other similar technologies) can serve a number of purposes. They allow us to better understand how users are using our website and other related services. They can also be an essential part of providing certain online functionality and are the basis of some security measures. They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website.

We take steps to notify all users of the CEFLEX website that cookies are in use on the site, and by continuing to use the site, we infer your agreement to our use of cookies and other similar technologies.

There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies.

They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.

More Information

Our uses of such technologies fall into the following general categories:

  1. Essential. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
  2. Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
  3. Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

The cookies currently in use on this site are as follows:

Website Analytics

We use Google Analytics to better understand what people look at on our website.

When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Google Analytics (which is controlled by Google).

The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data.

We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.

As analytics information is not personal data, we do not specifically ask for your prior consent.

Other Google Services

In addition to Google Analytics, we use a number of industry-standard Google services to provide particular pieces of website content. These include:

  • Google Fonts: We may use one or more of Google’s web fonts to ensure that our website content is displayed in a clear and consistent fashion across all of the different types of devices and browsers.
  • Google Recaptcha: We may use Google’s Recaptcha service (which provides the ‘I Am Not A Robot’ functionality) on our web contact forms. This is a security measure to prevent the abuse of our contact forms by automated programs.

Both of these services involve our website making a connection to one or more Google servers, and may result in Google placing cookies on your device.

More Information

Google Fonts

By using Google Fonts, we make a connection to the Google Fonts API and, unless your browser has already stored a copy of the font in use (by virtue of visiting another website that uses it), your browser will download a copy of that font. This all happens in near real time, and means that our website content will be displayed on your device in the way we had intended it, regardless of whether the particular font is installed on your device.

The Google Fonts API connection is unauthenticated, meaning that it will work regardless of whether you are logged into Google. It does not rely on cookies being sent to Google. Google may capture your device’s IP address as part of this process, and uses this data only in aggregate form to understand the popularity of individual fonts. More detail can be found on the Google Fonts FAQ page.

Lawful Basis

  • Under the Google Terms of Service we ask for your consent to process your personal data in this way (GDPR Article6(1)(a)) as part of this privacy policy. However, please note that this is not the only lawful basis on which we process this data
  • We consider that it is in our Legitimate Interest to process data in this way under GDPR Article 6(1)(f). The use of Google Fonts is a means of ensuring a clear and consistent display of our web content, in a way that improves user experience. The data collected by Google is extremely limited and we consider that it has negligible impact on individuals’ data privacy.

Google Recaptcha

We use the Google Recaptcha (‘I Am Not A Robot’) functionality to prevent automated programs (or ‘bots’) abusing our contact forms with spam messages or other malicious activity.

Before submitting a contact form to us, you will be asked to check the ‘I Am Not A Robot’ checkbox. In the background, Google will perform a number of checks that are aimed at understanding the likelihood of your being a ‘real’ person, as opposed to an automated system. If it is in any doubt, it will ask you to perform one or more activities (such as identifying particular items within an image) that only a ‘real’ person can do.

The exact mechanism for this is a closely guarded Google secret, but it does involve Google checking your activity on our (and other) websites and the presence/absence of any Google cookies in place on your device.

Lawful Basis

  • Under the Google Terms of Service we ask for your consent to process your personal data in this way (GDPR Article6(1)(a)) as part of this privacy policy. However, please note that this is not the only lawful basis on which we process this data
  • We consider that it is in our Legitimate Interest to use Recaptcha in this way under GDPR Article 6(1)(f). It enables us to maintain the security and integrity of our systems by minimising spam, and to provide an efficient service to ‘real’ users. On balance, we consider that it has a negligible impact on individuals’ privacy.