For the purpose of the General Data Protection Regulations 2016, and any and all other applicable laws and regulations relating to the processing of personal data (“the Data Protection Legislation”), Abacus is the data controller.
1. What types of personal data does Abacus collect?
Personal data means any information about any individual from which that person can be identified.
In the context of your organization’s membership in Abacus (or potential membership), collaboration or your participation to an Abacus event, Abacus may collect and process the following information about you from the information you provide to us:
· Basic Identity Data: includes name, gender, title, position and picture.
· Additional Identity Data: includes date of birth, signature, identity card or passport copy and visa information.
· Contact Data: includes email address, phone number and address.
· Financial Data: includes credit card details.
· Professional Data: includes key competences, practice area, special interests, CV/Bio, social media pages (such as your LinkedIn profile), memberships, languages spoken, private and business positions, insurances and information about transactions, referrals and deals concluded.
· Membership Data: travel arrangement details, accommodation preferences, participation in meetings and participation in optional activities.
· Special Category Data: includes health conditions, allergies and dietary preferences. Abacus will process Special Category Data in accordance with the Data Protection Legislation.
Abacus may also collect data about your (minor) children when they accompany you to events organized by Abacus. In that case, the information processed by Abacus may include their name, photo, accommodation dates, travel arrangement details, participation in optional activities and their identity card or visa (“Children Data”). Abacus will only process Children Data when it is necessary to do so for the purposes outlined above and unless any unusual circumstance apply (in which case you will be notified) will delete all personal data as soon as possible after the relevant event.
2. How we use your personal data
Abacus collects and processes information about you when the law allows us to. Abacus will use your personal information, where you act as the contact person or representative of your organization, in the following ways and for the following purposes:
· Basic Identity and Contact Data for the performance of the membership agreement that Abacus has with your organization including the organization of meetings, networking or conferences as is necessary for the performance of our membership agreement with your organization.
· Basic Identity and Contact Data for compiling and using general or specific mailing lists for sending newsletters, announcements (e.g. about new members) and information emails (e.g. related to a particular conference/event) where it is in our legitimate interests to do so. You may unsubscribe at any time from receiving further communications from us for these purposes.
· Basic Identity and Contact Data forlisting your details in the Abacus global directory which is publicly accessible online at www.abacusworldwide.org as is in our legitimate interests to do so.
· Basic Identity, Contact Data, Membership and Financial Data for organizing and executing Abacus activities (e.g. contacting members for participating in Abacus projects such as writing articles for the newsletter or publications on social media, matchmaking and networking, organizing social events and invoicing) as is in our legitimate interests to do so.
· Basic Identity and Contact Data for conducting analysis of the activities and the functioning of Abacus’ organization (e.g. post-event analysis based on the attendance of the delegates of the various sessions) as is in our legitimate interests to do so.
· Basic Identity, Contact and Professional Data for business development activities related to candidates for Abacus membership, potential partnerships and/or collaborations as is in our legitimate interests.
· Basic Identity and Contact Data for announcements on new members on social media and sharing of members’ articles on social media as is in our legitimate interests.
· Basic Identity and Contact Data for the inclusion in the Abacus website internal area downloadable Excel files as is in our legitimate interests.
· Special Category Data (being allergies and dietary information) for the organization of Abacus events which involve the provision of food and drink and to ensure your health and safety at Abacus’ events. Prior to processing any Special Category Data, Abacus will obtain your explicit consent to carry out such processing.
· For the purposes of the above, our ‘legitimate interests’ are for the promotion of Abacus’ business, the promotion of your organization and third parties involved in Abacus, the proper running of our business and the administration and organization of events, meetings and conferences held by Abacus. Our legitimate interests also include the maintenance of the goodwill and reputation of Abacus which involves the provision of excellent service to its members and prospects and the prevention of fraud and money laundering.
Abacus also has a legitimate interest in processing the personal data of representatives or contact persons of prospects in order to promote Abacus’ activities and membership and to inform prospects about Abacus’ opportunities.
3. Recipients of personal data
Abacus may share Basic Identity and Contact Data with other Abacus members (e.g. for referrals or recommendations or in the context of Practice Group activities) as is in our legitimate interests to do so.
Abacus may also share Identity and Contact Data, when it communicates publicly on the (new) membership of organizations (e.g. for marketing purposes and for the listing in the global rankings). Your Identity and Contact Data may also be communicated to the general public when Abacus sends newsletters or posts announcements via social media.
Abacus may also share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of Abacus or its employees. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction as is in our legitimate interests to do so.
4. Transfer outside the European Economic Area
Your data will be processed outside the European Economic Area (“EEA”) in the USA as Abacus is headquartered in the USA.
· We will only transfer your personal data to countries which have been recognized as providing an adequate level of protection of personal data, by the adoption of an adequacy decision by the European Commission (see
· In respect of third parties in the USA, we may transfer data to them if they are part of Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the USA.
· The use of standard data protection clauses approved by the European Commission.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5. Retention of your personal data
Abacus will process your personal data for no longer than is reasonably necessary for the purpose or those purposes it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
Abacus considers that an appropriate retention period for storing and using your personal data is for as long as your organization is a member or a prospect of Abacus and for as long you remain a representative for your organization. For further details of the retention periods of your personal data, please contact us at the email or postal address above.
We may retain your personal data for a longer period of time in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect of our relationship with you.
Where you have given us your consent to the specific processing of your personal data, you have the right to withdraw that consent at any time. Should you wish to withdraw your consent please contact us at the postal or email address above.
6. Storage and security of your personal data
All the information that you provide to us is stored on third party secured servers (such as Amazon/Microsoft/Google/Zoho cloud servers). Abacus has put in place measures to protect the security of your data. This includes security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Your rights as a data subject
In addition to the information contained in this data protection policy, you have the right to access the personal data which Abacus processes regarding you. Should the personal data that Abacus has regarding you be incorrect or incomplete, you are entitled to have the data rectified.
You have the right to request from Abacus the deletion or erasure of your personal data. Please note that in certain circumstances we may not be able to delete or erase your personal data such as where this is still required for the purpose for which it was provided or where we have overriding legitimate interests in retaining the data.
You are entitled to request the restriction of processing (temporarily) in the following scenarios:
· if the accuracy of the personal data is contested;
· the processing is unlawful and you prefer the restriction of the processing to the erasure of your data;
· if Abacus no longer needs your data except for the establishment, exercise or defense of legal claims; or
· while it is being verified whether your legitimate interests override Abacus.
You have the right to object to the processing, when the processing is based on Abacus’ or third party’s legitimate interests, on the basis of your particular situation. You have the right to object when you data are processed for direct marketing purposes by clicking the “unsubscribe” link.
You are entitled to receive the data concerning you in a structured, machine-readable format that is commonly used and you have the right to have the data transmitted to a controller of your choice (data portability).
You can exercise these rights by sending an e-mail to [email protected] or by post to PO Box 56-1166 Miami, FL 33256-1166.
Should you have a complaint concerning the processing of your personal data, you have the right to lodge a complaint with the competent national supervisory authority. However, we would appreciate the opportunity to deal with your concerns before you approach a supervisory authority so please contact us in the first instances.
If you require any assistance with identifying the appropriate supervisory authority, then please let us know.
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