Privacy

ICC PRIVACY POLICY

1. About ICC

The International Chamber of Commerce (ICC) is the world business organization, the only representative body that speaks with authority on behalf of enterprises from all sectors in every part of the world. ICC was founded in 1919. Today it groups over 6 million members in more than 100 countries.

The ICC International Secretariat is located at 33-43 avenue du Président Wilson, 75116 Paris, France. We can be reached by phone at +33 1 49 53 28 28 or by fax at +33 1 49 53 28 59.

ICC Corporate Chart

ICC Corporate chart

If you want to know more about ICC activities please visit the About ICC gateway of the ICC website.

 

2. ICC’s Privacy Statement

The purpose of this Privacy Policy is to inform you of the procedures regarding the collection, use and disclosure of information on the ICC website, including any mobile versions or related mobile applications, collectively called ICC Sites, accessible on: https://iccwbo.org/. ICC encourages you to carefully read this Privacy Policy.

The ICC website (hereinafter: the “Site”) is provided by ICC and/or its affiliates. By visiting the ICC Sites and providing information to ICC, you acknowledge that you have been informed and you consent to the Privacy Policy, including with regard to ICC, ICC affiliates, ICC National Committees and Groups’s use and disclosure of personal information which may be collected when you contact ICC, subscribe to ICC email alerts and newsletters, when you register for events,  trainings or on a plateforms, or when you request any other products and services provided by ICC in accordance with the purposes detailed in section 4. If you do not wish your personal information to be used by ICC in the manner set out in this Privacy Policy, please do not provide us this information.

 

3. Nature of information collected

3.1. Personal data that you provide voluntarily or that we receive through referrals

In order to receive ICC newsletters or information about ICC products and services, to contact ICC for any questions or comments, to request ICC products and services, or to register for ICC events, trainings or plateforms, you may choose to provide some personal information.

The categories of personal information that ICC may collect for the processing purposes described hereto are:

  • Identification data such as family name, first name;
  • Demographic data such as country of residence;
  • Professional data such as organization, job title, activity, main area of interest;
  • Contact data such as, email address and mobile phone number.

ICC will ensure that personal data collected from you is strictly necessary for the purposes described in section 4 below.

3.2. Personal data that we collect automatically

When you visit our website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (“EEA”), this information may be considered Personal Data under Applicable Data Protection Laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained in section 9 below.

 

4. Purposes of Data Processing

ICC will only use your personal data where permitted to do so by applicable law. Under GDPR, the processing is lawful only if and to the extent that one of the following legal basis applies:

  • Consent: you have given consent to our use of your information. You may withdraw your consent through unsubscribe link.
  • Contract performance: your information is necessary to enter into or perform a contract with you.
  • Legal obligation: your information is necessary to comply with our legal obligations
  • Legitimate interests: your information is necessary to pursue a legitimate interest

Our legal basis for collecting and using your information described below will depend on the personal data concerned and the specific contact in which we collect it.

 

ICC, or ICC affiliates, ICC National Committees and Groups, or processors on their behalf, may use the collected personal information:

  • To manage your membership to an ICC National Committee or to ICC.

The legal basis is legitimate interests, consent or contract performance.

  • To administer and perform our legal services – including to carry out our obligations arising from dispute resolution services.

The legal basis is contract performance, legitimate interest, consent or legal obligation.

  • To engage with you in ICC projects and activities.

The legal basis is legitimate interests, consent or contract performance.

For communication or marketing purposes – we can send newsalerts, newsletters, emails, or other communications relating to products and services that may be of interest. We will provide an option to unsubscribe or opt out of further communications.The legal basis is legitimate interests or consent.

  • To process and respond to your questions and/or inquiries.

The legal basis is legitimate interests.

  • For evaluation and development of ICC activities purposes – analysis in order to improve our services and offers. ICC, or third parties on its behalf, may also use information provided in an aggregate and anonymous form for internal business and planning purposes, including to analyse trends and statistics

The legal basis is legitimate interests.

  • To facilitate use of websites or plateforms.

The legal basis is legitimate interests, consent or contract performance.

 

5. Data retention

ICC will retain your personal data only for as long as it is necessary to complete the operations for which data has been collected or until you request to no longer receive communications from us, in accordance with applicable laws and regulations.

When you submit an enquiry to ICC via our “Contact Us” form, an email is sent directly to our secure email server. The details of your enquiry may be stored by ICC in our email archives.

 

6. Transfer of data

For the purposes mentioned in section 4, as a global organization, ICC may need to transfer and process your personal information in a country other than your country of residence and/or outside of the European Union, to/in countries which may have different data protection laws.

In this case, ICC will put in place appropriate and adequate operational, organizational, procedural, and technical measures in order to ensure the security and confidentiality of your personal data.

 

7. Security

Protecting your privacy and your personal information is a priority for ICC. ICC has taken reasonable measures to protect your personal information from loss, misuse and alteration. However, please be aware that no data transmission over the Internet or storage technology can be guaranteed to be 100% secure. ICC can only take steps to help reduce the risks of unauthorized access to information/data. Each individual using the Internet user can also take steps to help protect his/her personal information and is encouraged to do so to further minimize the likelihood that a security incident may occur.

 

8. Your rights

  • Right to request access, rectification, erasure, restriction processing, object to the processing, portability

The collected information is necessary for your registration and, more generally, for the purposes described in section 4. It is subject to data processing at ICC. In application of the French law on data protection and the European Regulation on the protection of natural persons with regard to the processing of personal data and of the free movement of such data (General Data Protection Regulation “GDPR”) you will benefit from the right to access, rectification, erasure, restriction processing, object to the processing, portability. If you wish to exercise these rights and obtain all relevant information, please contact us at dataprotection@iccwbo.org

In which circumstances can you exercise your rights with ICC?

  • Right of access

1. You have the right to obtain from the controller, confirmation as to whether or not your personal data is being processed, and, where that is the case, access to your personal data and the following information:

  1. the purposes of the processing;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations;
  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  6. the right to lodge a complaint with a supervisory authority;
  7. where the personal data is not collected from you, any available information as to it source;
  8. subject to the conditions provided by the GDPR, the existence of automated decision-making.

2. Where personal data is transferred to a third country or to an international organisation, you shall have the right to be informed of the appropriate safeguards relating to the transfer.

3. The controller shall provide a copy of the personal data undergoing processing. For any further copies you may request, the controller may charge a reasonable fee based on administrative costs.

4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

  • Right to rectification

You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  • Right to erasure (‘right to be forgotten’)
  1. You shall have the right to obtain from the controller the erasure of personal data without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
    1. the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
    2. you withdraw your consent;
    3. you object to the processing on grounds relating to your particular situation including profiling and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing;
    4. the personal data has been unlawfully processed;
    5. the personal data has to be erased for compliance in accordance with European Union or French law.
  1. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of the personal data.
  2. The right to erasure shall not apply to the extent that processing is necessary for:
    1. exercising the right of freedom of expression and information;
    2. compliance with a legal obligation to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
    3. archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing;
    4. the establishment, exercise or defence of legal claims.
  • Right to restriction of processing

1. You shall have the right to obtain from the controller restriction of processing where one of the following applies:

  1. you contested the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
  2. the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of its use instead;
  3. the controller no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;
  4. you have objected to processing on grounds relating to your particular situation including profiling pending the verification of whether the legitimate grounds of the controller override yours.

2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

3. When you have obtained restriction of processing pursuant to paragraph 1, you shall be informed by the controller before the restriction of processing is lifted.

  • Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform you about those recipients if you request it.

  • Right to data portability

1. You shall have the right to receive personal data which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided, where:

  1. the processing is based on consent; and
  2. the processing is carried out by automated means.

2. In exercising your right to data portability pursuant to paragraph 1, you shall have the right to have your personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of your right to data portability shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4. The right to data portability shall not adversely affect the rights and freedoms of others.

  • Right to object
  1. You shall have the right to object, on grounds relating to your particular situation, at any time to processing which is based on legitimate interests. The controller shall no longer process your personal data, unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
  2. Where personal data is processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  3. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
  4. At the time of the first communication with you, the right referred to in paragraphs 1 and 2 shall be explicitly brought to your attention of the data subject and shall be presented clearly and separately from any other information.
  5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
  6. Where personal data is processed for scientific or historical research purposes or statistical purposes, you, on grounds relating to your particular situation, shall have the right to object to processing of your personal data, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • Right to object to automated individual decision-making, including profiling

1. You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

2. This right shall not apply if the decision:

  1. is necessary for entering into, or performance of, a contract between you and the data controller;
  2. is authorised by European Union or French law and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
  3. is based on your explicit consent.

3. In the cases referred to in sub-paragraph (i) and (iii) above, the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, including the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

  • Right to unsubscribe

If you no longer wish to receive communications from ICC, you may opt out by cancelling your subscription on the ICC Site through the link sent in each email you receive from ICC, or by sending an email to ICC_Connect@iccwbo.org.

 

9. Cookies Policy

  • General

Subject to your prior explicit consent where such consent is required by the applicable law in your jurisdiction, ICC Sites use “cookies” (i.e., small text files which are downloaded to a user’s device when visiting the ICC Sites) in order to improve navigation around the ICC Sites for the user and improve the quality of the ICC Sites.

By using https://iccwbo.org/, you consent to the use of cookies. If you do not consent to such use, you may disable these cookies through your browser.

  • Which cookies are we using?
    • ICC uses cookies to save your logged in status and track that you have visited the site. This is useful for you and means that you do not have to login to access your preferences each time you visit the ICC website. This is also useful for us as it helps us gauge how many users have visited our site.

The Site also uses Google Analytics with the anonymizer function, a web analytics service provided by Google. Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the websites and/or apps that use Google Analytics. Google Analytics uses IP addresses to derive the geolocation of a visitor, and to protect the service and provide security to our customers. When anonymizer function is enabled, Google Analytics uses only a portion of an IP address collected, rather than the entire address. The last octet of the user’s IP address prior to its use and storage is removed, which means that the full IP address is never written to disk. This does slightly reduce the accuracy of geographic reporting.
More information on Google Analytics is available under: https://support.google.com/analytics/answer/6004245
More information about IP Anonymization in Analytics: https://support.google.com/analytics/answer/2763052?hl=en

Parameters of web browsers by default are generally set up in such a manner to accept cookies but you can easily change those parameters by modifying your preferences. If you choose to deactivate cookies, some functionalities, pages or parts of the ICC Site may not be accessible. ICC is not responsible in such cases.

For more information related to cookies parameters, you can consult the following websites:

CNIL – http://www.aboutcookies.org/en
Internet Explorer™ – http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies 
Safari™ – http://support.apple.com/kb/ht1677?viewlocale=fr_FR
Chrome™ – https://support.google.com/chrome/answer/95647?hl=fr
Firefox™ – https://support.mozilla.org/fr/kb/activer-desactiver-cookies

 

10. Links to Other Sites

The https://iccwbo.org/ site may contain links to or from a number of third party websites (hereinafter referred to as “Third Party Sites”). ICC does not, in any way, control or operate the Third Party Sites. ICC is not responsible for the privacy practices, content, policies or actions of the Third Party Sites. This Privacy Policy is only applicable to general information processed by the ICC Sites, pursuant to information collected on ICC Sites. The use of any information you may provide to third parties on Third Party Sites, or which such parties may otherwise collect on other websites, is not governed by this Privacy Policy.

 

11. Social Networks

Social media plug-ins of social networks such as Facebook, Twitter and LinkedIn or services with user-generated content features are integrated into the ICC Sites. Where the ICC Sites contain a plug-in to a social network site, these are clearly marked (e.g. with a Facebook button). If you choose to click on one of these buttons or links, your browser connects directly to the servers of the relevant social network. The other website’s privacy policy applies to any personal information you provide to that website. If you do not want the social network to collect the information about you, please review the privacy policy of the relevant social network and/or log out of the relevant social network before you visit the ICC Site.

 

12. Intellectual Property (IP) / Content

All content displayed on the ICC Sites, including but not limited to, text, graphics, logos, buttons, icons, images, sounds, audio clips, digital downloads, data compilations and software, is the property of ICC or its content suppliers and is protected by the French and/or foreign applicable laws.

Registered trademarks of ICC are marks indicated on the ICC Sites and include licensors, in France and other countries. All other trademarks that appear on the ICC Sites are the property of their respective owners.

You are prohibited from using, without permission, any of the marks, trademarks, trade names, service names, logos or other proprietary graphic appearing throughout the ICC Sites. For more information, please read the Copyright section on this website.

 

13. Updates to Privacy Policy

To the extent permitted by applicable law in your jurisdiction, ICC may, from time to time, revise or update this Privacy Policy. You agree to be bound by such modifications or updates. If we make material revisions to the way we collect or use your personal information such that we are using it for purposes that you have not consented to, we will notify you of the changes and, as the case may be, ask for your explicit consent.

Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Internet, accessible through the ICC Sites. By continuing to use the ICC Sites following such changes, you will be deemed to have agreed to such changes.

 

Last updated 09/10/2018

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