Privacy Notice

ILGA-Europe ("We", "us", "our"), is the umbrella for over 600 LGBTI organizations in Europe and Central Asia. With the goal to contribute to the development of our collective capacities as the LGBTI movement in these regions, We created The Hub, a resource-sharing center, an online platform where activists can share their own successes and learning. 

We are committed to complying with EU Privacy Law. This privacy notice (the "Notice") describes how We process the Personal Data We collect from The Hub-registered-users and reference contacts ("You", "your"). If You are a reference contact, section 1 does not apply to You. 

We are a data controller. This means that We are responsible for deciding how We collect and use (Process) Personal Data about You. We are required under GDPR to notify You of the information contained in this Notice. This is not the only place where you will find information on our use of your data; to know how we use cookies on The Hub, please look at our Cookies Notice in the bar displaying at the bottom.

1. What Personal Data do We hold about You? How we collect Personal Data, for Which Purposes and on Which Legal Basis?

Depending on the purposes of the processing, We collect different Personal Data from You. These are listed below. 

  1. To create your account and allow You to access our resources, We Process your name, email address, password, location, and organization (optional).
  2. To send You our newsletter and updates, We Process your name and email address.
  3. When You submit a case study publication, we Process your name, photo, email address, location, organization (optional), and the content of your case study. We would like to post your email and case study on our platform, in order for members of The Hub to be able to contact You. If You do not wish so, we will post it on an anonymous basis (that however doesn’t mean that your identity will not be shared with us).
  4. When You submit your idea / feedback using our form, We Process your name (and may link its content to You).
  5. When You fill in the contact form, We Process your name, email and your message. We use this Personal Data to respond to your query and be in touch with You.

Please note that the content of the case study, your feedback/ideas or the message You share with us in our contact form might include Personal Data (that might not be Yours). This type of content might also include Special Categories of Data (e.g., data concerning sexual orientation even if only implied by association). In order to limit our processing of Personal Data and Special Categories of Data, we ask You to consider whether it is strictly necessary for You to share any of such data with us. 

We typically collect Personal Data from You. We do so based on your consent. You can withdraw your consent at any time, as indicated in Section 6.

2. Specific Information in relation to our Verification Process. 

We use the verification process for the purpose of confirming the identity of our registered users and allow them to access sensitive content on the Hub. 

If You are the registered user, We Process your name and email address to reach out the contacts and organization You identified as reference and share your name and email address with them. We do so on the basis of your consent. 

If You are the reference person, we process your name and name of the organization You work with in order to verify the identity of a registered user. We collect your Personal Data from a registered user or, in very limited circumstances, from public sources (e.g., if the email provided by the registered user is outdated). We do so based on our legitimate interest, as We believe it is in our interest to secure access to sensitive information on The Hub. In doing so, We considered your rights and expectations as a Data Subject and have assessed that your interest, fundamental rights and freedoms are not put at risk. We limit the processing of your Personal Data to what is strictly necessary for the purpose of verifying a user account and delete your information as soon as it is done. To know what specific rights You have in this regard, you can refer to Section 6 below.

3. Which third-parties process your Personal Data and for which purpose? Do We Share, Disclose or Transfer Personal Data?

We share or disclose your Personal Data with third parties, including third-party service providers. 

In particular, We share your Personal Data with:

  1. CiviCooP, Zijlstraat 10, 5305 EE Zuilichem, The Netherlands, the company that hosts our email lists;
  2. OVH SAS, 2 rue Kellermann, 59100 Roubaix, France, the company that hosts our platform; and 
  3. The reference contact, if You are a registered user and ask us to verify your account. 

Where We rely on those third parties for the Processing of your Personal Data, We put safeguards in place to ensure that the third party is obligated to provide at least the same level of data protection as the one We offer You. 

We do not use other third-parties to process your Personal Data or otherwise transfer Personal Data outside of the EEA and/or disclose your Personal Data to other recipients than those mentioned in this Notice. If We were to do so, We will comply with EU Privacy Law.

4. Change of purpose

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. 

5. How long will We retain your Personal Data?

We retain your Personal Data in accordance with our Retention/Destruction Guidelines. As a general principle, We keep your Personal Data only for as long as You do not withdraw your consent, or as long as it is necessary or as long as You don't object to the Processing. 

6. Your rights in connection with Personal Data

Under certain circumstances, by law You have the right to:

  1. Request access to your Personal Data. This enables You to receive a copy of the Personal Data We hold about You and to check that We are lawfully processing it. You can request an export of your data by clicking Send me all my data here.
  2. Request correction of the Personal Data that We hold about You. This enables You to have any incomplete or inaccurate information We hold about You corrected.
  3. Request erasure of your Personal Data. This enables You to ask us to delete or remove personal information where there is no good reasons for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where You have exercised your right to object to Processing (see below). You can do that by clicking the button Delete account here.
  4. Object to Processing of your Personal Data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes You want to object to the Processing on this ground. 
  5. Request the restriction of Processing of your Personal Data. This enables You to ask us to suspend the Processing of Personal Data about You, for example if You want us to establish its accuracy or the reason for Processing it.
  6. Request the transfer of your Personal Data to another party (data portability). 

Once You provided your consent to the collection and Processing of your Personal Data, You have the right to withdraw your consent for that specific Processing at any time. 

To withdraw your consent, object to the Processing, exercise any of your rights as Data Subject, or make queries or complaints, please contact the person in charge of privacy compliance at ILGA-Europe either via email: bjorn@ilga-europe.org or by post to: ILGA-Europe, Rue du Trône/Troonstraat 60, 1050 Brussels, Belgium – subject to including a copy of an official form of identification.

If You are dissatisfied with any aspect of our handling of your Personal Data, You have the right to make a complaint at any time to the Supervisory Authority.

It is important that the Personal Data We hold about You is accurate and current. Please change your account information here to keep us informed of any changes to your personal information. 

7. Effect of Notice and changes to Notice

We may revise this privacy notice from time to time and any revisions will be made available to You via email and via our website https://hub.ilga-europe.org/.

8. Our contact details 

ILGA-Europe

Rue du Trône/Troonstraat 60

1050 Brussels

Belgium

Telephone: + 32 2 609 54 10 

Fax: + 32 2 609 54 19

9. Glossary 

In this Notice:

"EU Privacy Law" means the General Data Protection Regulation 2016/679 ("GDPR") and the Belgian national privacy laws, as amended from time to time. 

"Data Subject" means an identified or identifiable individual. 

"Personal Data" means any information relating to an identified or identifiable natural person. 

"Processing" means any operation performed on Personal Data, manually or by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Special categories of Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

"Supervisory Authority" means the Belgian Data Protection Authority or the relevant data protection authority of the data subjects' habitual residence or place of work.

Version No. 1

6th of October 2020