How we respect privacy when we deal with personal information collected by our organisation.
This Privacy Statement applies to data we, Microinsurance Network a.s.b.l., collect about individuals who interact with our organisation. It explains what personal data we collect and how we use it. Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
If you have any questions or comments about this notice, feel free to contact us at info@microinsurancenetwork.org.
1. Personal data that we process
The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.
| Purpose | Data (key elements) | Legal basis |
|---|---|---|
| Enquiring about our organisation and its work | Name, email, message | Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way you would expect. |
| Subscribing to email updates about our work (e.g. newsletter) | Name, email | Consent – you have given your active consent. |
| Keeping members updated | Name, email | Consent – by becoming a member, you have given your active consent to receive email updates sent to members of the Network. |
| Receiving or making payments | Name, email, address, payment information | Legitimate interests – this information is necessary for us to process payments. |
| Signing up as a member | Name, email, address, organisation | Contract – by paying your membership fees you have entered into a contractual relationship with us as set out in our Articles of Association (Bylaws). |
| Website functionality | Website activity collected through cookies | Legitimate interests – it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of form submission before you have fully completed the process. |
2. How we use your data
We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this privacy statement.
For example, we may use your personal information to:
• reply to enquiries you send to us;
• handle donations or other transactions that you initiate;
• where you have specifically agreed to this (e.g. by becoming a member), send you email updates and invitations to events relating to our work which we think may be of interest to you.
3. When we share your data
We will only pass your data to third parties in the following circumstances:
• you have provided your explicit consent for us to pass data to a named third party;
• we are using a third party purely for the purpose of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of the third party data processors; or
• we are required by law to share your data.
In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation (GDPR).
4. How long we keep your data
We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required. Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.
5. Rights you have over your data
You have a range of rights over your data, which include the following:
• Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).
• You have the right to ask for rectification and/or deletion of your information (“right to be forgotten”).
• You have the right of access to your information.
• You have the right to lodge a complaint with the National Commission for Data Protection (CNPD) Information Commissioner if you feel your rights have been infringed.
Chapter 3 of the GDPR specifies your rights as a data subject.
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.
Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.
6. Cookies & usage tracking
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users' computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google's privacy policy is available at {http://www.google.com/privacypolicy.html}.
7. Modifications
We may modify this Privacy Statement from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we'll notify people whose personal data we hold and who are affected.