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Last updated: [1 June 2021].
This website is operated by the Bussola Institute on behalf of ourselves ("Bussola Institute", "we", "our" or "us").
We recognise that when you provide us with information about yourself, you trust us to act in a responsible manner. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This applies to personal information that we collect though the Website or when engaging in our relationship or potential relationship with you (or your organisation).
Who are we and what do we do?
The Bussola Institute is an independent, not-for-profit, non-governmental organisation established in Brussels in 2017 dedicated to a strong relationship between the countries of the Gulf Cooperation Council (GCC) and the European Union (EU). The vision of the Bussola Institute is to be a world-class Research Institute that is acknowledged as the premier source of understanding and knowledge concerning relations between Europe and the Gulf. The Mission of the Bussola Institute is to generate and share information and knowledge, that fosters improved understanding and promotes stronger Gulf-European relations through rigorous research and objective analysis.
The Bussola Institute is an AISBL/IVZW (an international non-profit organisation incorporated under Belgian law), located at De Meeûssquare 28, 1000 Brussels, Belgium and registered at the Crossroads Bank for Enterprises under the number 0672.588.991 (RPR/RPM Brussels).
You can find more information about our company and on how to reach us via our contact page.
What information do we collect?
Depending on your relationship with the Bussola Institute, we may collect personal information about you that broadly falls into the following categories:
Information that you provide voluntarily
Information that we collect automatically
Information that we obtain from third party sources
In order to comply with various regulations, or to conduct background checks in accordance with our internal requirements (where permissible and in accordance with applicable law), sometimes we may receive personal information about you from third party sources. We will only obtain this information where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us or if this information is publicly available. In any case, we will only collect such information if we are legally allowed to do so and have the required legal basis (see below), such as legitimate interest, your consent or a legal obligation.
Sensitive personal information
Normally, we will not process any sensitive personal data ('special categories of data') about you. In exceptional circumstances we may however need to process such data, which will only happen where permitted (or imposed) by, and in accordance with, applicable law.
You may also provide us with information about a health condition to facilitate us making adjustments to ensure accessibility to premises and/or events. If you provide us with information about another person, you confirm that they have appointed you to act for them, that you have informed them of our identity and the purposes (as set out in this Privacy Notice) for which their information will be processed and that you have obtained any necessary consents to the processing of their personal information. When we first contact them, we will inform them where we obtained the information.
Processing of such sensitive data will always/only occur in strict compliance with the applicable rules, such as art.9 of the GDPR.
How do we use your personal information?
We use your personal information essentially for the following purposes (or otherwise described at the point of collection):
To deliver our services, organise our events, conduct our research, communicate with you, etc.
To maintain and develop our website:
For general company administration purposes:
Who do we share your personal information with?
We may disclose your personal information to the categories of recipients described hereafter. These are not allowed to use this data themselves for their own purposes. These parties will only gain access to your (raw) personal data if and to the extent that such access is strictly necessary for the processing purposes described above.
Categories of recipients:
Legal basis for processing personal information
Under European Union data protection law, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we need the personal information to perform a contract with you, where the processing is in our legitimate interests and not overridden by your rights, or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where we process your sensitive personal information, we do so: in the context of know-your-counterparty checks as required by applicable law; on the basis that the processing is necessary for reasons of substantial public interest; on the basis of your explicit consent; or to establish, exercise or defend legal claims.
You can choose not to provide personal information to us. However, unless otherwise indicated, the information that we request is necessary for the purposes described above and failure to provide it may impede for example the contracting process and/or the provision of the relevant services.
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will for example be to provide our services to you, respond to your queries, improve our Website(s), undertake marketing, or for the purposes of detecting or preventing illegal activities.
Given the context in which we undertake the processing of your personal information, and the safeguards that we take to protect your personal information, our legitimate interests are not outweighed by any prejudice to your individual rights and freedoms. If the latter would be the case, we would stop further processing. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in the Contact Us section of the website or the contact information provided below.
How do we protect your information?
Technical security measures
For example, in terms of access (login requirements, password policy, role division, etc.), storage (encryption, backup, etc.), and protection against outside access (firewall, antiviral software, etc.) of the media on which personal data can be stored.
This includes raising awareness among employees and service providers concerning the importance of privacy, the enforcement of policies, the continuous maintenance of a data register, compliance with a data policy, etc.
If we process your personal data based on grounds of legitimate interest (such as processing for prospection purposes to persons we have no prior relationship with), we will conduct a “legitimate interest assessment” (or “balancing test”) to assure that additional safeguards are foreseen and applied. This way, we guarantee a proportionate and balanced processing of your data in accordance with the privacy legislation.
Despite the security measures that we take, it is important to know that the transfer of data via an Internet connection is never without risks and you must take the necessary precautions when you are connected with the Internet in order to protect yourself from viruses, malware, etc.
International data transfers
We will process your personal data as much as possible within the EU. Some of our (current or future) service providers and affiliated companies may however process your personal data outside of the EU. In such cases we ensure that an appropriate level of protection is offered as required under the GDPR.
Specifically, our Website servers are in Belgium, and our affiliated companies and third-party service providers may operate around the world. This means that when we collect your personal information, we may process it in any of these countries.
Further details about the protection given to your personal information can be provided upon request by contacting us using the details in the Contact Us section of the website or the contact information provided below.
We retain personal data we process from you as long as necessary for the abovementioned purposes..
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
If European data protection laws apply, you have the following rights:
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the Contact Us section of the website or the contact information provided below.
In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the Contact Us section of the website or the contact information provided below.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the 'unsubscribe-link' in any mail you receive from us or by emailing us at firstname.lastname@example.org; subject: opt me out). To opt-out of other forms of marketing (such as postal marketing), then please contact us using the contact details provided under the Contact Us section of the website or the contact information provided below.
Similarly, if we have process your personal data based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Links to other websites
We link to other websites. We are not responsible for the content or privacy policies of these websites for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for these websites or advertisers nor are we authorised to make representations on their behalf. In any event, you should explore the privacy practices of those third parties.
i) To guarantee and improve the operation of our website;
ii) To remember you;
iii) To show you targeted publicity;
iv) To let you share content from our website on social media;
v) To analyse, improve, and personalise the use of our website;
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.
The use of our website is subject to our Website Terms [/link].
How to contact us
If you have received an e-mail or e-mails from the Bussola Institute that you no longer wish to receive, please contact us at email@example.com. If you otherwise have any questions or concerns about our use of your personal information, please contact us at: firstname.lastname@example.org.
The data controller of your personal information is the entity (i) with which you or your organisation is engaged as a supplier or customer; (ii) which is considering entering a relationship with you or your organisation; and/or (iii) with which you are engaged as user of a particular service provided by the Bussola Institute.
©ALL RIGHTS RESERVED EXCLUSIVELY TO THE BUSSOLA INSTITUTE
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