{"id":3,"date":"2022-05-31T15:01:59","date_gmt":"2022-05-31T15:01:59","guid":{"rendered":"https:\/\/euroly.org\/?page_id=3"},"modified":"2022-06-29T17:58:04","modified_gmt":"2022-06-29T17:58:04","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/euroly.org\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"
\n

Privacy Policy<\/h1>\n
\n

The Euro-Libyan Trade Center respects your privacy and is committed to protecting your personal data. This privacy policy explains how we look after your personal data and tell you about your privacy rights and how the law protects you.<\/p>\n<\/div>\n<\/div>\n

\n

1. IMPORTANT INFORMATION AND WHO WE ARE<\/h4>\n

1.1. Purpose of this privacy notice:<\/p>\n

This privacy notice aims to give you information on how the Euro-Libyan Trade Center collects and processes your personal data (including through your use of this website).<\/p>\n

This website is not intended for children and we do not knowingly collect data relating to children.<\/p>\n

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.<\/p>\n

1.2. Controller:<\/p>\n

The Euro-Libya Trade Center is the controller and responsible for your personal data (collectively referred to as the Euro-Libyan Trade Center, \u201cELTC\u201d “we”, “us” or “our” in this privacy notice).<\/p>\n

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your\u00a0legal rights, please contact the data privacy manager using the details set out below.<\/p>\n

1.3. Contact details:<\/p>\n

Our full details are:<\/p>\n

    \n
  • \n
      \n
    • \n
        \n
      • Full name of legal entity: Euro-Libyan Trade Center LTD<\/li>\n
      • Email address: info(@)eurolibyan.com<\/li>\n
      • Postal address: 71-75 Shelton St, London WC2H 9JQ<\/li>\n
      • You have the right to make a complaint at any time to the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

        1.4. Change to the privacy notice and your duty to inform us of changes:<\/p>\n

        This version was last updated on July 2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.<\/p>\n

        1.5. Third-party links:<\/p>\n

        This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.<\/p>\n

        2. THE DATA WE COLLECT ABOUT YOU<\/h4>\n

        Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).<\/p>\n

        We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:<\/p>\n

          \n
        • \n
            \n
          • If you are\u00a0a visitor to the Site or\u00a0prospective member:\n
              \n
            • First name; Last name; Email address; Job title and Company name.<\/li>\n
            • Technical Data\u00a0includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.<\/li>\n<\/ul>\n<\/li>\n
            • If you are\u00a0a member or client of the ELTC:\n
                \n
              • Identity Data\u00a0includes first name, last name, username or similar identifier, job title, title.<\/li>\n
              • Contact Data\u00a0includes billing address, correspondence address, email address and telephone numbers.<\/li>\n
              • Regulatory Data\u00a0includes relevant information as required by regulatory Know Your Client or Anti Money Laundering regulations. (HMRC)<\/li>\n
              • Transaction Data\u00a0includes details about payments to and from you and other details of products and services you have purchased from us.<\/li>\n
              • Technical Data\u00a0includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.<\/li>\n
              • Profile Data\u00a0includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.<\/li>\n
              • Marketing and Communications Data\u00a0includes your preferences in receiving marketing from us and your communication preferences.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

                3. HOW IS YOUR PERSONAL DATA COLLECTED?<\/h4>\n

                We use different methods to collect data from and about you including through:<\/p>\n

                  \n
                • \n
                    \n
                  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:\n
                      \n
                    • apply for our products or services;<\/li>\n
                    • create an account on our website;<\/li>\n
                    • subscribe to our services or publications;<\/li>\n
                    • register as a candidate for recruitment services on our website;<\/li>\n
                    • request marketing to be sent to you\u00a0or give us some feedback.<\/li>\n<\/ul>\n<\/li>\n
                    • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our\u00a0cookie policy below for further details.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

                      4. HOW WE USE YOUR PERSONAL DATA<\/h4>\n

                      We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:<\/p>\n

                        \n
                      • \n
                          \n
                        • Where we need to perform the contract we are about to enter into or have entered into with you;<\/li>\n
                        • Where we need to carry out requests made by you on the website or in relation to our services<\/li>\n
                        • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.<\/li>\n
                        • Where we need to comply with a legal or regulatory obligation;<\/li>\n
                        • Where we provide support for the provision of our services<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

                          Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.<\/p>\n

                          See below to find out more about the types of lawful basis that we will rely on to process your personal data.<\/p>\n

                          4.1. Purposes for which we will use your personal data:<\/p>\n

                          We have set out below, in a table format, a description of all the ways we plan to use your personal data (depending on your relationship with the ELTC), and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.<\/p>\n

                          Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.<\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n
                          \n

                          Purpose\/Activity<\/p>\n<\/td>\n

                          		\n

                          Type of data<\/p>\n<\/td>\n

                          		\n

                          Lawful basis for processing including basis of legitimate interest<\/p>\n<\/td>\n<\/tr>\n<\/thead>\n

                          \n

                          To register you as a new member<\/p>\n<\/td>\n

                          		\n

                          (a) Identity
                          (b) Contact<\/p>\n<\/td>\n

                          		\n

                          Performance of a contract with you<\/p>\n<\/td>\n<\/tr>\n

                          \n

                          To process and deliver your order including:
                          (a) Manage payments, fees and charges
                          (b) Collect and recover money owed to us<\/p>\n<\/td>\n

                          		\n

                          a) Identity
                          (b) Contact
                          (c) Financial
                          (d) Transaction
                          (e) Marketing and Communications<\/p>\n<\/td>\n

                          		\n

                          (a) Performance of a contract with you
                          (b) Necessary for our legitimate interests (to recover debts due to us)<\/p>\n<\/td>\n<\/tr>\n

                          \n

                          To manage our relationship with you which will include:
                          (a) Notifying you about changes to our terms or privacy policy
                          (b) Asking you to leave a review or take a survey<\/p>\n<\/td>\n

                          		\n

                          (a) Identity
                          (b) Contact
                          (c) Profile
                          (d) Marketing and Communications<\/p>\n<\/td>\n

                          		\n

                          (a) Performance of a contract with you
                          (b) Necessary to comply with a legal obligation
                          (c) Necessary for our legitimate interests (to keep our records updated and to study how members use our products\/services)<\/p>\n<\/td>\n<\/tr>\n

                          \n

                          To comply with our legal obligations (including HMRC. Know Your Client, Anti-Money Laundering or similar obligations<\/p>\n<\/td>\n

                          		\n

                          (a) Identity
                          (b) Contact<\/p>\n<\/td>\n

                          		<\/td>\n<\/tr>\n
                          \n

                          To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)<\/p>\n<\/td>\n

                          		\n

                          (a) Identity
                          (b) Contact
                          (c) Technical<\/p>\n<\/td>\n

                          		\n

                          (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
                          (b) Necessary to comply with a legal obligation<\/p>\n<\/td>\n<\/tr>\n

                          \n

                          To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you<\/p>\n<\/td>\n

                          		\n

                          (a) Identity
                          (b) Contact
                          (c) Profile
                          (d) Marketing and Communications
                          (e) Technical<\/p>\n<\/td>\n

                          		\n

                          Necessary for our legitimate interests (to study how members use our products\/services, to develop them, to grow our business and to inform our marketing strategy)<\/p>\n<\/td>\n<\/tr>\n

                          \n

                          To use data analytics to improve our website, products\/services, marketing, member relationships and experiences<\/p>\n<\/td>\n

                          		\n

                          (a) Technical<\/p>\n<\/td>\n

                          		\n

                          Necessary for our legitimate interests (to define types of members for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)<\/p>\n<\/td>\n<\/tr>\n

                          \n

                          To make suggestions and recommendations to you about goods or services that may be of interest to you<\/p>\n<\/td>\n

                          		\n

                          (a) Identity
                          (b) Contact
                          (c) Technical
                          (e) Profile<\/p>\n<\/td>\n

                          		\n

                          Necessary for our legitimate interests (to develop our products\/services and grow our business)<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                          4.2. Marketing:<\/p>\n

                          We need your consent for some aspects of these activities which are not covered by our legitimate interests (the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we will ask for this via an opt-in or soft-opt-in (which we explain further below).<\/p>\n

                          Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by virtue of your membership, attending an ELTC event). Under \u2018soft opt-in\u2019 consent, we will take your consent as given unless or until you opt out. You can opt out at any time by clicking on the unsubscribe button present in all our communications.<\/p>\n

                          For other types of e-marketing, we are required to obtain your explicit consent.<\/p>\n

                          4.3. Third-Party Markeing:\u00a0<\/p>\n

                          We will get your express opt-in consent before we share your personal data with any company outside ELTC for marketing purposes.<\/p>\n

                          4.4. Opting out:<\/p>\n

                          You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or following the opt-out links on any marketing message sent to you at any time.<\/p>\n

                          4.5. Cookies:<\/p>\n

                          You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. More information about our cookie\u00a0policy\u00a0here.<\/p>\n

                          4.6. Change of purpose:<\/p>\n

                          We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.<\/p>\n

                          5. DISCLOSURES OF YOUR PERSONAL DATA:<\/h4>\n

                          We may have to share your personal data (depending on your relationship with the ELTC) with the parties set out below for the purposes set out in the table above:<\/p>\n

                            \n
                          • \n
                              \n
                            • External Third Parties as set out in the Glossary.<\/li>\n
                            • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.<\/li>\n
                            • We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
                                \n
                              • \n
                                  <\/ul>\n<\/li>\n<\/ul>\n

                                  6. INTERNATIONAL TRANSFERS:<\/h4>\n

                                  We do not transfer your personal data outside the European Economic Area (EEA).<\/p>\n

                                  7. DATA SECURITY:<\/h4>\n

                                  We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.<\/p>\n

                                  8. DATA RETENTION<\/h4>\n

                                  8.1. How long will you use my personal data for?<\/p>\n

                                  We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.<\/p>\n

                                  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.<\/p>\n

                                  If you want to learn more about our specific retention periods for your personal data established in our retention policy you may contact us at info(@)eurolibyan.com<\/p>\n

                                  Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.<\/p>\n

                                  In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.<\/p>\n

                                  9. YOUR LEGAL RIGHTS<\/h4>\n

                                  Under certain circumstances, you have rights under data protection laws in relation to your personal data. And more specifically on these rights:<\/p>\n

                                    \n
                                  • \n
                                      \n
                                    • Request access to your personal data<\/li>\n
                                    • Request correction of your personal data.<\/li>\n
                                    • Request erasure of your personal data.<\/li>\n
                                    • Object to processing of your personal data.<\/li>\n
                                    • Request restriction of processing your personal data.<\/li>\n
                                    • Request transfer of your personal data.<\/li>\n
                                    • Right to withdraw consent.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

                                      If you wish to exercise any of the rights set out above, please contact\u00a0info(@)eurolibyan.com<\/p>\n

                                      9.1. No fee usually required:<\/p>\n

                                      You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.<\/p>\n

                                      9.2. What we may need from you:<\/p>\n

                                      We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.<\/p>\n

                                      9.3. Time limit to respond:<\/p>\n

                                      We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.<\/p>\n

                                      10. GLOSSARY<\/h4>\n

                                      10.1. Lawful basis:<\/p>\n

                                        \n
                                      • \n
                                          \n
                                        • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service\/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities in the paragraph above \u201cPurposes for which we will use your personal data\u201d.<\/li>\n
                                        • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.<\/li>\n
                                        • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

                                          10.2. Third parties external:<\/p>\n