Webinar Privacy Notice
INFORMATION NOTICE PURSUANT TO
ART. 13 REGULATION (EU) 2016/679 ON 27TH APRIL 2016
Alira Health (or “Alira”), as the Controller of personal data, is committed to comply with the GDPR and all applicable data protection laws and regulations. Alira wants to ensure that you understand what personal data is collected in connection with your participation in the Event, how this information is used, and how it is stored.
Personal Data will be processed lawfully, fairly and in a transparent manner; will be collected for specified, explicit and legitimate purposes and processed in a manner that is not incompatible with such purposes; they will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed, accurate and up-to-date; they will be processed with the utmost confidentiality, mainly with electronic and automated means, and stored both electronically and on paper, and on any other type of suitable means, in accordance with the principles of the General Data Protection Regulation 2016/679 (GDPR), the requirements given by the supervisory authority and, in any case, in such a way as to ensure adequate level of security, including protection, with adequate technical and organizational measures, from non-authorized or unlawful processing, or even accidental loss. Data will be stored in a manner that permit the identification of the data subjects for the extent strictly necessary to the achievement of the purposes for which they were processed.
Alira Health, as defined below, undertakes the responsibility to observe specific security measures in order to prevent data loss, illegitimate or unfair use and unauthorized access, in full compliance with statutory and regulatory provisions.
The Personal Data voluntarily provided by yourself will be stored in Alira Health database exclusively for the purposes specified below and for a limited time or for the time required by the relevant legislation.
1. Identity and contact details of the Data Controller
For the purposes of this Notice, Data Controller(s), independently or jointly, are the companies of Alira Health Group separately or together referred to as “Alira Health” and/or “Data Controller”.
Alira Health companies have signed an agreement as Joint Controllers available for your consultation, on request.
2. Contact details of the Data Protection Officer
In accordance with the GDPR, Alira has appointed a Data Protection Officer (DPO).
For the purposes of exercising the rights provided for in the GDPR, and for any request relating to your personal data, you may contact Alira’s DPO by sending a communication to the following e-mail address: [email protected]
3. What data do we process?
- General information collected: surname, first name, company, job title, business e-mail address, signature, country/region of residence, bank details (if necessary for payment);
- Photographs taken during the Event (if you attend the Event in person) with your consent;
- The recording (which may include your face and voice) of your presentation is made during the Event.
4. How and why do we use this information?
- Organize your participation in the event: allow you to register for the event, confirm your registration, communicate about the organization of the event, check that you are registered when you arrive at the event, …
- External communication about the event:
- With your authorization, Alira Health SAS and its Affiliates, will process your photos, videos and recordings (Images) taken during the event organized by Alira Health
- Namely through publication by means of company advertising channels; through publication on the website, in company presentations and on company advertising material (brochures, advertisements).
- Provision to participants of a recording of the presentations, for a limited time, after the event.
- If you agree, we may also use your personal data for:
- marketing purposes (namely sending of advertising material, market research, newsletters, and commercial communication)
As a general rule, you can always withdraw your consent, opt-out of an application or unsubscribe from a newsletter.
5. On what legal basis do we use your personal data?
- The legal basis for the processing of your data in order to organize your participation in the Event is the contractual obligation of Alira, in the context of your registration for the Event. If you do not provide us with the necessary data in this context, it will not be possible to properly manage your registration for the Event.
- The legal basis for the processing of your data in order to externally communicate about the Event (via the taking and use of photographs taken during the event where you may appear) is your consent.
- The legal basis for the recording and making available of the recording of presentations made during the Event (on which you may appear) is your consent. Two situations must be distinguished:
You attend the Event in person:
If you attend the event in person, your consent to the use and disclosure of your image, as well as consent to the processing of your personal data, will be requested through a form provided upon arrival.
You attend the Online Event:
If you participate in the Online Event, we draw your attention to the fact that your camera is turned off by default and that, if you turn it on, you may appear as part of the recording of presentations. If you do not wish to appear on the recording, please keep your camera off. However, if you turn on your camera, you change the initial settings set by default, which means that you perform a clear positive action by which you understand and accept that your face may appear on the recording that will be provided to the participants. You will be reminded of this at the beginning of the event.
- With regard to promotional activity, Alira, as Data Controller, hereby informs that the personal data you voluntarily provide will be processed for the following purposes, with your consent:
- Marketing Activities (sending of advertising material, market research, commercial communication);
The legal basis related to Data processing for marketing purposes is your consent.
Following this information notice the consent for promotional activity can be accorded. The refusal to give consent for promotional activities will not prevent from the participation to the webinar.
6. Data sharing: Recipients or categories of recipients of Personal Data
We do not sell, trade or transfer your personal data to third parties. However, if you agree that your photographs may be used to communicate about the event after it has taken place, you should be aware that these photographs may appear on Alira websites and/or on social networks.
Recordings of presentations made during the event will be provided to the registrants and may be publicly available for a limited period after the event.
Third parties involved in the webinar which will process personal data for the aforementioned purposes are entitled to process such data and will act in accordance with the principles of the GDPR. It is hereby specified that the third parties to whom personal data are provided for the aforementioned marketing purposes will act in accordance with the principles of the GDPR.
Personal data acquired by Alira Health are not subject to dissemination. These data may be communicated within the Alira Health group and be known by the persons tasked with data processing in accordance with the principles of the GDPR.
For the purposes of maintenance of this website, Alira Health may use third parties, who therefore may have access to your data. However, these individuals will be appointed as Data Processors or authorized persons tasked with data processing, and will receive adequate operating instructions, particularly in relation to the adoption of minimum security measures.
Your personal data can only be processed by GoTo Webinar (website host and payment provider). For more information on the data processing carried out by GoTo Webinar, you can consult the privacy notice available on their website at https://www.goto.com/company/legal/privacy/us
7. How long do we keep your information?
Alira will keep your personal data for a period not exceeding that necessary for the aforementioned purposes and in any case, no more than 3 years after the end of the event and in any case until the data subject withdraws the consent to data processing when applicable.
8. Transfer of Personal Data to third countries
Data processing may be carried out in a Member State of the European Union (EU), in a Member State of the European Economic Area (EEA) or in a Third Country. In case of transfer of data to a recipient established in non-EU third countries, the transfer is subject to specific provisions to protect personal data in compliance with the GDPR. Therefore, Alira has committed to comply with those provisions (Chapter V of the GDPR).
For the purposes specified, Alira Health uses the platform Zoho CRM, which is managed by the company ZOHO CORPORATION B. V, with registered office at Beneluxlaan 4B, 3527 HT Utrecht, the Netherlands including ZOHO CORPORATION PVT. LTD. incorporated and registered in India whose registered office is at Estancia IT Park, Plot No. 140 & 151, GST Road, Vallancherry Village, Chengalpattu Taluk, Kanchipuram District 603 202, INDIA by adopting data protection clauses set forth by the European Commission.
9. Mandatory or optional nature of data communication
The communication of your personal data is a contractual requirement. The refusal to communicate them will prevent Alira to register you to participate to the webinar.
For purposes that rely on your consent, the provision of your personal data is optional. The refusal to communicate them will not prevent you to participate to the webinar.
10. Existence of an automated decision-making process
Alira Health does not use any automated decision-making process.
11. How do we protect your information?
ALIRA treats your personal data confidentially and uses at least the same level of care in safeguarding your personal data as used with its own confidential information of a similar nature.
Your personal data is stored on secure systems and is only accessible by a limited number of people with special access rights and who are bound by confidentiality obligations.
12. Your rights
Based on the GDPR, you have the following rights:
- Information: You have the right to be informed about the processing of your personal data;
- Access: You have the right to obtain confirmation that personal data concerning you are or are not being processed and, where applicable, all the information necessary to make the processing of your data transparent;
- Rectification: You have the right to demand the rectification of inaccurate or incomplete data concerning you;
- Erasure: You have the right to request the erasure of your personal data incertain circumstances;
- Restriction of processing: You have the right to restrict the processing of your data in certain specific circumstances;
- Data portability: You have the right to receive or have your personal data transferred to another organisation in a machine-readable form;
- Objection: You have the right to object at any time, for reasons relating to your particular situation, to the processing of your data;
- Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling; and
- Right to withdraw your consent: Where you have given your consent for the processing of your data, you may withdraw it at any time without justification.
Please, note that these rights are not absolute and will be assessed on a case-by-case basis.
If you wish to exercise any of these rights, you can contact Alira’s Data Protection Officer: [email protected]
You also have the right to lodge a complaint with the data protection authority of the state of your habitual residence, place of work, or place of alleged infringement if you believe that your personal data is not being processed in accordance with the GDPR.
13. Contacts
Alira Health
1 Grant Street, Suite 400
Framingham, Massachusetts 01702
United States
+1 (774) 777 5255
Alira Health DPO
Data Protection Authorities
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm