Privacy Policy
1. Introduction
This privacy statement explains the reason for the processing of
your personal data, the way we collect, handle and ensure protection of all
personal data provided, how that information is used and what rights you have
in relation to your personal data. It also specifies the contact details
of the responsible Data Controller with whom you may exercise your rights, the
Data Protection Officer and the European Data Protection Supervisor.
Your privacy is important to us. When we collect, manage
and use your data to run our services, we take all steps necessary to ensure
that your data is stored securely and used only in accordance with the
preferences you have requested. We will not share your data unless you
have given us permission to share it. We will not process your data for
any other purposes.
2. Why and how do we process your personal data?
You directly provide Whombuy.com with most of the data we
collect. We collect data and process data when you:
Become a Whombuy.com Aggregator
Register and participate in one of our online or offline events,
programmes, calls or grants.
Voluntarily complete a survey, provide feedback or participate
in an impact assessment
Register to become a member of the Whombuy.com Network
Association
Sign up to obtain an Whombuy.com API Key
Download the Whombuy.com Impact Playbook
Sign up to have access to the Whombuy.com website personal space
to create own galleries or like content
Contribute content, metadata and/or stories to the Whombuy.com
collections
Use or view our website via your browser's cookies.
Whombuy.com may also receive your data indirectly from the
aggregation of digital cultural heritage to the Whombuy.com website. We
display digital objects and metadata provided by data partners and other
contributors via the Whombuy.com website which may contain personal data.
Whombuy.com collects your data so that we can facilitate your
participation in an event or other activity, send you the information you have
requested, manage your account, inform you of changes to our terms and
conditions, where relevant, or email you with information when you have asked
us to.
When you become a member of the Whombuy.com Network Association,
your name and other identification information is made available online. Your
personal data may also be published online if it is part of content or metadata
featured in Whombuy.com collections.
When you participate in a ticketed event, we will share your
name, and sometimes your email address and other identification information
with the other attendees at that event to facilitate networking activities.
3. On what legal ground(s) do we process your personal data
For specific processing activities, the consent of the data
subject is necessary. In compliance with Article 3(15) and Article 7 of
Regulation (EU) 2018/1725, the consent must be freely given, specific, informed
and unambiguous.
You have given consent to the processing of your personal data
for one or more specific purposes (Article 5(1)(d) of Regulation (EU)
2018/1725).
We have obtained your consent directly from you. You may
have expressed it by an email, submitted via e-registration form, or in any
other written form.
4. Which personal data do we collect and further process?
Whombuy.com collects the following data:
Personal identification information (Name, email address,
professional information, social media profiles).
Profile picture or personal image. We collect this
information for Whombuy.com Network Members, panelists to our events and other
activities, with your consent.
(Statistical) Information about gender and age. We collect
this information occasionally and anonymously to have an understanding of the
diversity of participants in our events and services.
Health-related information. We occasionally collect
health-related information such as visual or hearing impairments to ensure we
can support you in participating in our online or offline activities.
5. How long do we keep your personal data?
The first time you directly supply personal information, we
create a record of your data and store that record in our internal systems. Whombuy.com
securely stores your data in both cloud services, and Whombuy.com servers
(located at PSNC in Poland), and at private companies, located in Germany and
Finland.
If you are a member of the Whombuy.com Network Association, your
record will be allocated a unique identification number.
Whombuy.com will keep your personal data only for as long as
necessary to provide you with the service you have requested, such as keeping
your account up to date or maintaining your network membership status. Once
this time period has expired, we will delete your data.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents,
databases, uploaded batches of data, etc.) are stored either on the servers of
the Whombuy.com Foundation, based in Poznan, Poland, or of its contractors. Our
contractors are bound by a specific contractual clause for any processing
operations of your data on behalf of Whombuy.com, and by the confidentiality
obligations deriving from the General Data Protection Regulation ('GDPR'
Regulation (EU) 2016/679).
In order to protect your personal data, we have put in place a
number of technical and organizational measures to address online security,
risk of data loss, alteration of data or unauthorized access, and restricting
access to the personal data solely to authorized persons with a legitimate need
to know for the purposes of this processing operation.
7. Who has access to your personal data and to whom is it
disclosed?
As a general criterion, we do not communicate data to third
parties.
Access to your personal data is provided to Whombuy.com staff
responsible for carrying out this processing operation and to authorised staff
according to the “need to know” principle. Such staff abide by statutory,
and when required, additional confidentiality agreements.
Furthermore, access to your personal data can be provided to
external contractors working on behalf of and under contractual agreement with
Whombuy.com.
When issuing invoices to customers, the data can be communicated
to banks. In justified cases, we will communicate the data to the security
bodies or forces or to the competent judicial bodies.
No data transfers are made outside the scope of the European
Union (international transfer).
The information we collect will not be given to any third party,
except to the extent and for the purpose we may be required to do so by law.
8. What are your rights and how can you exercise them?
You have specific rights as a 'data subject' under Chapter III
(Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to
access, rectify or erase your personal data and the right to restrict the
processing of your personal data. Where, you also have the right to object
to the processing or the right to data portability.
You have the right to object to the processing of your personal
data, which is lawfully carried out pursuant to Article 5(1)(a).
You have consented to provide your personal data for the present
processing operation. You can withdraw your consent at any time by
notifying the Data Controller. The withdrawal will not affect the
lawfulness of the processing carried out before you withdraw your consent.
You can exercise your rights by contacting the Data Controller,
or in case of conflict the Data Protection Officer. If necessary, you can
also address the European Data Protection Supervisor. Their contact
information is given under Heading 9 below.
Where you wish to exercise your rights in the context of one or
several specific processing operations, please provide their description (ie
their Record reference(s) as specified under Heading 10 below) in your request.
9. Contact information
The Data Controller: If you would like to exercise your rights
under Regulation (EU) 2018/1725, or if you have comments, questions or
concerns, or if you would like to submit a complaint regarding the collection
and use of your personal data, please feel free to contact the Data Controller
Unit G2, Directorate G, Directorate - General
for Communications Networks, Content and Technology (DG CNECT) of the European
Commission at: info@whombuy.com
The Data Protection Officer (DPO) of Whombuy.com: You may
contact the Data Protection Officer (info@whombuy.com) with regard to issues
related to the processing of your personal data under Regulation (EU)
2018/1725.
The European Data Protection Supervisor (EDPS): You have the
right to have recourse (ie you can lodge a complaint) to the European Data
Protection Supervisor (info@whombuy.com) if you consider that your rights under
Regulation (EU) 2018/ 1725 have been infringed as a result of the processing of
your personal data by the Data Controller.
10. Privacy policies of other websites
Our websites contain links to other websites. Our privacy
policy applies only to our website, so if you click on a link to another
website, you should read their privacy policy.
11. Changes to our privacy policy
Whombuy.com keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 19 May 2021.