1. Introduction
2. Definitions
3. ZDHC Academy
4. Access to ZDHC Academy
5. Provision and Use of Data 
6. Training Material
7. Maintenance and Support
8. Disclaimer
9. Limitation of Liability
10. Additional provisions

Annex 1: ZDHC Privacy Policy 

The ZDHC Academy is provided by the Implementation Hub B.V.(Implementation Hub), a wholly owned subsidiary of the Stichting ZDHC Foundation (ZDHC Foundation). ZDHC Foundation is a not for profit organisation having its official seat in the municipality of Amsterdam (the Netherlands) that facilitates the ZDHC Roadmap to Zero Programme (Programme) to advance towards zero discharge of hazardous chemicals in the textile, apparel and footwear (including leather) industries (Industry) through the widespread implementation of sustainable chemistry, driving innovations and best practices in the Industry to protect consumers, workers and the environment. 

To support the ZDHC Foundation’s mission and vision and also the delivery of the Programme, ZDHC Foundation has developed a wide range of ZDHC centric training relating to all aspects of chemical management organised and delivered – as the case may be supplemented by additional training content – by third party service providers appointed by Implementation Hub (Accredited Training Providers). The aim of the Training is to provide knowledge and practical guidance to participants (Training Participants) for the implementation of ZDHC Foundation tools, guidelines and any and all other ZDHC Foundation products and/or offerings. All Training is organised via this platform, the ZDHC Academy. 

Please read these User Terms and Conditions (‘Terms and Conditions’) carefully. By using the ZDHC Academy you agree to the Terms and Conditions and to be bound by all the provisions stated herein. 

Consent to Processing of Personal Data:

In the course of Registration or use of the ZDHC Academy you will be asked to provide Personal Data. By registering you declare your explicit consent to the processing of the Personal Data within ZDHC Academy. The consent may be withdrawn at any time which will not affect the lawfulness of the processing before the consent was withdrawn.

Implementation Hub declares that all Personal Data will be stored and processed in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

For more details see the ZDHC Privacy Policy (Annex), in particular Annex 1 -Appendix A, which Implementation Hub appropriates.

ZDHC Academy provides the web-based platform to Users to organise Training related to ZDHC’s activities in the field of chemical and environmental management and sustainability. The delivery of Training is subject to a separate agreement between Training Participants and Accredited Training Providers. Modifications and enhancements of the ZDHC Academy such as functional enhancements, new features and other modifications may be implemented at the sole discretion of Implementation Hub.  

By Registration to ZDHC Academy the User is granted a revocable, non-exclusive, non-transferable, non-sub-licensable right to use the platform. The ZDHC Academy User-ID and Password necessary for logging into the ZDHC Academy shall be issued and assigned to the User by Implementation Hub. The User-ID and Password issued to a User may be used by such User only. The User shall not disclose, lend or assign to any third party the User-ID and Password for logging into the platform. Implementation Hub may suspend use of ZDHC Academy by any User who is determined to be unsuitable, in particular for breaching these Terms and Conditions or otherwise impeding or disrupting any other user’s use of ZDHC Academy.

​​​​​5.1 Agreement. User agrees that Data provided to ZDHC Academy such as contact details, date and availability of Training, prices etc. will be made available to other Users for the purpose of organisation and delivery of Training. Implementation Hub will impose the obligation on all Users to use the Data only for those purposes (see clause. 5.3).

5.2 Correctness of Data. Responsibility for the accuracy of Data entered into ZDHC Academy lies solely with the User entering (or having entered) the Data. User understands that ZDHC does not guarantee or verify that Data entered into ZDHC Academy are accurate or reliable and that, while all users must agree to only enter accurate information into the Information System, User understands and agrees that sole reliance upon the Data is at User’s own risk.

​​​​​​​5.3 Limitations. User agrees not to use Data obtained from ZDHC Academy for other purposes than the organisation and delivery of Training. In particular, User shall not use Data for any purpose which is unlawful, prohibited by any applicable law or regulation or is inconsistent with the aims of ZDHC Academy or ZDHC Foundation.

Training conveyed through ZDHC Academy is based on Training Material developed and provided by ZDHC Foundation and, in some cases, modified and/or supplemented by Accredited Training Providers. User acknowledges that ZDHC Foundation and,where appropriate, the Accredited Training Provider are the copyright owners of the Training Material. The Training Material must not be used for any purpose other than the education and training of the User. In particular, the Training Material shall not be used to provide trainings or any other services related or similar to ZDHC Academy’s activities to any third party.

Implementation Hub will ensure regular and ongoing maintenance of the ZDHC Academy to correct bugs or other errors in the platform.  Maintenance will be scheduled so as to cause as minimal interference with User usage as reasonably possible.  During the maintenance, User may experience slowdowns or outages.  Reasonable efforts will be made to complete maintenance within the designated maintenance window.

THE ZDHC ACADEMY IS PROVIDED "AS IS" WITHOUT ANY WARRANTY, AND USER’S USE OF THE ZDHC ACADEMY IS SOLELY AT USER’S OWN RISK. IMPLEMENTATION HUB DOES NOT WARRANT THAT THE ZDHC ACADEMY WILL MEET USER’S REQUIREMENTS OR THAT THE OPERATION WILL BE UNINTERRUPTED OR ERROR-FREE. TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW, IMPLEMENTATION HUB DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS, IMPLIED, AND STATUTORY, CONCERNING THE ZDHC ACADEMY OR OTHERWISE RELATED TO THESE TERMS AND CONDITIONS, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE OR ARISING FROM A COURSE OF DEALING OR USAGE OF TRADE, AND ANY STATUTORY WARRANTIES OF NON-INFRINGEMENT. 

EXCLUDING DAMAGES ARISING FROM OR OUT OF GROSS NEGLIGENCE, WILLFUL MISCONDUCT OR FRAUD, IN NO EVENT SHALL IMPLEMENTATION HUB’s LIABILITY EXCEED €20,000 (fifty thousand Euros). EXCLUDING DAMAGES ARISING FROM OR OUT OF GROSS NEGLIGENCE, WILLFUL MISCONDUCT OR FRAUD, TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW IN NO EVENT SHALL IMPLEMENTATION HUB BE LIABLE TO ANYONE FOR ANY INDIRECT, PUNITIVE, SPECIAL, EXEMPLARY, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY TYPE OR KIND (INCLUDING LOSS OF DATA, REVENUE, PROFITS, USE OR OTHER ECONOMIC ADVANTAGE) ARISING OUT OF, OR IN ANY WAY CONNECTED WITH THE ZDHC ACADEMY, INCLUDING BUT NOT LIMITED TO THE USE OR INABILITY TO USE THE ZDHC ACADEMY, OR FOR ANY CONTENT OBTAINED FROM OR THROUGH THE ZDHC ACADEMY, OR ANY INTERRUPTION, INACCURACY, ERROR OR OMISSION, REGARDLESS OF CAUSE, IN THE CONTENT, EVEN IF THE PARTY FROM WHICH DAMAGES ARE BEING SOUGHT OR SUCH PARTY'S LICENSORS HAVE BEEN PREVIOUSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. 

10.1 Governing Law and Jurisdiction.  The use of ZDHC Academy shall be governed by Dutch Law, without regard to the choice or conflicts of law provisions of any jurisdiction, and any disputes, actions, claims or causes of action arising out of or in connection with the use of Information System shall be subject to the exclusive jurisdiction of the courts located in the Netherlands.

10.2 Total Agreement.   These Terms and Conditions constitute the entire agreement and understanding between User and the Implementation Hub with respect to the subject matter hereof and supersedes all prior or contemporaneous agreements, any representations or communications with respect to accessing the ZDHC Academy. The Terms and Conditions may be amended by Implementation Hub and User will receive notification of such amendment. In order to access the ZDHC Academy, User will need to click “Agree” to the amended Terms and Conditions.

​​​​​​​10.3 Non-Waiver.  No waiver by either party of any breach or default of any covenant or agreement set forth in these Terms and Conditions shall be deemed a waiver as to any subsequent and/or similar breach or default.

​​​​​​​​​​​​​​10.4 Severability.  In the event that, any of the provisions contained in these Terms and Conditions is held to be invalid, illegal, or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provisions of these Terms and Conditions, and these Terms and Conditions shall be construed as if the invalid, illegal, or unenforceable provisions had never been contained in it.

Version 1.0 June 2018.

Last Update: 04/06/2018

ZDHC is taking the opportunity to update its privacy policy1 for services to make it easier to understand what information and data2 ZDHC collects and why (Policy).  For ‘personal data’ (see below) this policy takes into account requirements of the EU General Data Protection Regulation (known as GDPR) and as provided for in the ZDHC Privacy Notice (Appendix A). This policy is included as part of the applicable User Terms and Conditions relating to ZDHC Services and is shared on relevant web-based Services. 

This Policy is for users of ZDHC web-based products and services including and not limited to the ZDHC Gateway, ZDHC Academy, ZDHC Intranet (Contributors only), ZDHC event registration tool (together called Services) and is intended to clarify the following:

1. the types of information collected by ZDHC;
2. how ZDHC uses, stores and processes collected information; and
3. how individuals (for personal data) and organisations can have their information reviewed, updated, or removed.

1 This privacy policy covers a range of information and data types and including ‘personal data’ within the meaning of the EU General Data Protection Regulation.

2 Throughout this policy ZDHC uses the words ‘information’ and ‘data’ interchangeably and to mean the same thing.

The mission of Stichting ZDHC Foundation (ZDHC) is to enable the textile, apparel, and footwear industries (the Industry) to implement sustainable chemical management best practice across the value chain. Through collaborative engagement, standard setting, and implementation, ZDHC will advance towards zero discharge of hazardous chemicals. The ZDHC vision is the widespread implementation of sustainable chemistry, driving innovations and best practices in the Industry to protect consumers, workers and the environment.   ZDHC believes that providing standards and tools, fostering collaboration and joint implementation among industry stakeholders across the value chain leads to improved chemical management in the Industry supply chain, and ultimately improves the livelihoods of consumers and workers, and the environment. 

For activities that are part of Services ZDHC collects, processes and controls different kinds of information and data from a number of stakeholders including Contributors, industry partners as well as other stakeholders and individuals acting on behalf of those organisations. 

ZDHC collects the following four types of information (including data) (Information).

1.1. Personal Information

Many of ZDHC's Services require the user to sign up for an account. To create an account ZDHC may ask for personal Information such as name, email address, phone number.

1.2. Organisational Information

In the case where an individual signs up on behalf of an organisation (legal entity) such as a corporation, association or other organisation, ZDHC may ask for organisational Information such as legal entity, place of business, address and contact details, bank and tax details etc.

​​​​​​​1.3. Operational Information

Some of the Services provided by ZDHC relate to operational Information such as general product information, test reports, and including chemical management, sustainability and environmental information; users may be requested or required to upload such information.

​​​​​​​1.4. Meta Information

While using ZDHC's Services or viewing content provided by ZDHC, ZDHC will automatically collect and store certain Information in server logs; ZDHC files information such as internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp or number of clicks.

In general, all Information collected by ZDHC aims at and is limited to providing/maintaining/improving Services or developing new Services in connection with ZDHC goals and activities (see About ZDHC). In pursuing this objective ZDHC may use the different types of Information as set out below.

2.1. Personal and Organisational Information 

Both personal Information and organisational Information are used exclusively to grant access to ZDHC's Services and to allocate any operations and/or transactions within these Services to a specific user.  We always ask explicit consent, having given clear, transparent insight into what information will be used and how. For rights granted to data subjects in relation to personal data pursuant to GDPR please see Appendix A - ZDHC Privacy Notice.

2.2. Operational Information

Operational Information is used only to provide Services that enable and support ZDHC to pursue its mission and vision (see About ZDHC). In this context, ZDHC may use operational Information for benchmarking and statistical purposes. Operational Information is only disclosed to third parties to the extent that the Information provider has agreed in advance to such disclosure e.g. by explicitly accepting applicable user terms and conditions. In that case, ZDHC will impose the obligation on the third party (to whom the Information is disclosed) to only use the Information for purposes related to the goals and objectives of ZDHC and with full recognition of the data providers intellectual property rights. 

​​​​​​​2.3. Meta Information

Meta Information is not linked to any identifiable Information whether personal, organisational or operational. It is used exclusively to understand meta Information and trends e.g. by producing statistical reports, monitoring Services and analysis. 

Meta Information will not be used for purposes other than those set out above unless one of the following circumstances applies:

• The data provider/subject provides its express consent.
• External processing: ZDHC provides Information to its affiliates or other trusted businesses or persons to process it, based on ZDHC's instructions and in compliance with ZDHC's privacy policy and any other appropriate confidentiality and security measures.
• Legal reasons: ZDHC will share Information with companies, organisations (including governmental authorities) or individuals outside ZDHC if ZDHC has a belief in good faith that access, use, preservation or disclosure of the Information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, including outside of the EU.  ZDHC would use meta Information to 
  • enforce applicable user terms of service, including investigation of potential violations
  • detect, prevent or otherwise address fraud, security or technical issues
  • protect against harm to the rights, property or safety of ZDHC, the Services users of the Services or the public, as required or permitted by law.

ZDHC strives to enable users of Services who deliver proof of their identity and authorisation to access, review and update Information that has been provided by them quickly and effectively unless this infringes the fundamental operating principles or objectives behind the Services in question. 

For Personal Data the data subject should refer to the procedures outlined in the ZDHC Privacy Notice (Appendix A)

ZDHC PRIVACY NOTICE 

Version 1.0 May 2018.

Last Update: 24/05/2018

Important Note:  The current version of this Privacy Notice will always be available on https://www.roadmaptozero.com/privacy-policy/.   In the event of a discrepancy between the version in this Appendix the version online shall apply.

This Privacy Notice explains the types of personal data we may collect about you when you interact with us at ZDHC. It also explains how we store and handle that data, and keep it safe.

We know that there’s a lot of information here, however aim is to fully inform you on what personal data ZDHC collects, how ZDHC uses your data and importantly your rights in connection with your personal data.  We hope the following sections will answer any questions you have but if not, please get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, and you’re welcome to come back and check it whenever you wish.

The mission of Stichting ZDHC Foundation ('ZDHC') is to enable the textile, apparel, and footwear industries (the "Industry") to implement sustainable chemical management best practice across the value chain. Through collaborative engagement, standard setting, and implementation, ZDHC will advance towards zero discharge of hazardous chemicals. The ZDHC vision is the widespread implementation of sustainable chemistry, driving innovations and best practices in the Industry to protect consumers, workers and the environment.   ZDHC believes that providing standards and tools, fostering collaboration and joint implementation among industry stakeholders across the value chain leads to improved chemical management in the Industry supply chain, and ultimately improves the livelihoods of consumers and workers, and the environment.

In connection with these activities, ZDHC collects and processes different kinds of information and data from a range of different stakeholders including ZDHC Contributors, organisations that have an official (approved) role within our systems, industry partners and other individuals acting on behalf of those organisations. 

With regard to the personal data we collect we act as a controller of data processing. As such we are fully responsible for the adherence to the requirements of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation – GDPR). 

Our full contact details are:

Stichting ZDHC Foundation
Watersteeg 3
1012 NV Amsterdam
The Netherlands

E-Mail: media@zdhc.org

The law on data protection sets out a number of different reasons for which an organisation may collect and process your personal data, including:

1.1 Consent

In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service. You can also opt out at any time.

1.2 Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations. Information such as your name or place of work may be needed as part of creating a contract with ZDHC.

1.3 Legal compliance

If the law requires us to, we may need to collect and process your personal data. For example, we may need to hold onto your name, address, organisation data, and payments made to ZDHC for auditing and tax purposes.

1.4 Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of operating the activities of the ZDHC Roadmap to Zero Programme and the ZDHC Foundation, and any related activities and services and which does not materially impact your rights, freedom or interests.

For example, if you set up an account in our event registration tool and purchase an event ticket from us:

• We’ll collect your address details and VAT number to generate your invoice;
• We will pass your name and job title onto a printer for printing your event name badge.
• We will use your email address details to send you the event agenda and any updates on the event
• We may ask for feedback on the event.

When you visit our websites or platforms, and use your account to buy tickets to an event or meeting for example the ZDHC Annual Meeting or the SAC-ZDHC Manufacturer Forum.

When you create an account with us on our systems and platforms and/or when you need personal details changed or updated.

When your organisation applies to become and if approved becomes one or more of the following, we request personal contact information which is in support of the organisational information:

• A ZDHC Contributor.
• A ZDHC Accredited Training Provider (ATP).
• A ZDHC Accepted Certification Standard within the ZDHC Gateway - Chemical Module.
• A ZDHC Provisionally Accepted Laboratory within the ZDHC Gateway - Wastewater Module

When you download or install any apps we work with, like the SAC & ZDHC Manufacturer Forum app.

When you contact us by any means with queries, complaints etc.

When you ask one of our team or other relevant stakeholders to send you information or answer a query on ZDHC.

When you choose to complete any surveys we send to you and request you to complete.

When you agree to collaborate on creating a case study or any other marketing material.

Before we get into more detail, we want to be clear that we do not collect the following personal data:

• When you engage with us on our social media channels.
• About children.
• The great majority of personal data falling with the following categories of sensitive data: physiological data, mental identity, economic identity, social identity, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, sexual orientation, genetic data, biometric data or criminal offences/convictions. 

Finally, we do not sell personal data to any third parties.

If you have a web account with us, e.g. on the ZDHC intranet or our event registration tool, we will collect: your name, billing/delivery address, email and telephone number. For your security and to reset your password (when requested by you) we also keep an encrypted record of your login password.

Details of your interactions with us through email, face to face, telephone/conference calls will be stored on our customer relationship management system. 

When you make a purchase on our event tool we will see some encrypted information on your credit or payment card number.

Where the law requires this, copies of documents you provide to us to prove your age or identity for example your passport / driver's licence. This is likely to include details of your full name, address, date of birth and a facial image, gender and nationality. All such provided data is not stored by us and is deleted after we have used it only for this legally required purpose.

Details of your visits to our websites or apps, and which site you came from to ours.   

Information gathered by the use of cookies in your web browser. 

Of course, it’s always your choice whether you share such personal data with us. 

We want to give you the best possible experience of dealing with ZDHC. One way to achieve that is to create the richest picture we can of you by combining the data we have on you. We then use this to offer you opportunities to collaborate that are most likely to interest you. For example, perhaps you don’t want to commit to becoming a ZDHC Contributor, but would like to engage in the ZDHC Gateway or perhaps you could become a ZDHC Accredited Training Provider.  By gathering a certain amount of information, we can communicate and engage with you more effectively.  The data privacy law allows this as part of our legitimate interest in understanding our stakeholders and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details about how to do that in the ‘What Your Rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us for updates on events, but withdrawn your email address data, we may not be able to provide this kind of information.

Here are some more specific information on how we’ll use your personal data and why:

1. To process any orders you make to attend a ZDHC hosted or co-hosted paid for event by using the ZDHC event registration tool. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.  Your details may need to be passed to a trusted third party to provide a payment gateway for you to purchase an event ticket. We may keep your details for a reasonable period afterwards only to fulfil any contractual obligations such as refunds.
2. To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. 
3. To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
4. To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
5. If we discover any criminal activity or alleged criminal activity, we will process this data for the purposes of preventing or detecting unlawful acts. 
6. We always strive to protect the brand equity of any organisations who support ZDHC’s work and will act immediately in the event of a breach of ZDHC guidelines thereof.
7. With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, telephone or otherwise about relevant events, meetings, sponsorships and so forth that may be of interest to you.
8. To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, and legally required information relating to your activities with ZDHC. These messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
9. To develop, test and improve the systems, services and offerings we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
10. To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
11. To send you survey and feedback requests to help improve our services and activities. These messages will not include any promotional content and do not require prior consent when sent by email.  We have a legitimate interest to do so as this helps make our products or services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.

To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across ZDHC and third parties such as our data processors and as we have described in the section 'What Personal Data Do We Collect?' We do this on the basis of our legitimate business interest.

For example, by combining this data, this will help us decide which activities or content to share with you. 

Sometimes, we’ll need to share your details with a third party who is providing a service (such as a payment gateway). We do so to maintain our (contractual) obligation to you – for example to host a paid for event. Without sharing your personal data, we’d be unable to fulfil your request.

We want to bring you information most relevant to your interests at particular times. To help us form a better, overall understanding of your needs, we combine your personal data gathered across ZDHC as described above, for example your event ticket purchasing history. For this purpose, we combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us. By doing so we practice automated decision-making within the meaning of GDPR.

We know how much data security matters to all our stakeholders. We treat your personal data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of the ZDHC intranet and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data such as payment card information is secured and tokenised to ensure it is protected.

We monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.  Put another way, we will not hold onto or store personal data that is no longer needed.

At the end of an appropriate and reasonable retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Here are some examples of customer data retention periods: 

• Event Tickets - when you buy an event ticket, we’ll keep the personal data you give us for a maximum of one year so we can comply with our legal and contractual obligations. 
• Newsletter Subscriptions - when you have a regular subscription with ZDHC, we’ll keep the personal data you give us for a maximum of three years so we can comply with any legal and contractual obligations. 

We sometimes share your personal data with trusted third parties such as contracted data processors. For example, payment gateways. Here’s the policy we apply to these organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific contractually agreed services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them and monitor their activities to ensure your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our websites, platforms and other business systems.
• Operational companies such as delivery couriers.
• Companies who help us manage our electronic communications with you.
• Google/Facebook/LinkedIn to share our updates with you. This is based on either your marketing consent or your acceptance of cookies on our website. 
• Payment gateway providers to facilitate handling payments for event tickets

We generally do not share your data with third parties for their own purposes and when we do it’s in very specific circumstances, for example:

• With your consent, given at the time you supply your personal data, we may pass that data to a third party such as a collaboration partner for their direct marketing purposes.
• For example, if we run a joint event with another party, and you agree to receive direct communications from them e.g. following the SAC-ZDHC Manufacturer Forums.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take your privacy into consideration.

To help personalise your journey through our websites and platforms we currently use the following companies, who will process your personal data as part of their contracts with us:

ADEC Innovations; Amfori; Consulting 1X1; Mailchimp; Piwik Analytics; Prosperworks; Stripe; Survey Monkey; ZDHC Finance.

In this context we may transfer your personal data to it-infrastructure located in the United States of America. The transfer is covered by adequacy decision (EU) 2016/1250 as of 12^th July 2016. ZDHC’s partners processing the personal data complies to the Privacy Shield Agreement.

You have the right to request:

1. Access to the personal data we hold about you, free of charge.
2. The correction of your personal data when incorrect, out of date or incomplete.
3. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or the purpose for which we hold the data has come to an end (such as the end of an event).
4. That we stop using your personal data for direct marketing (either through specific channels, or all channels).
5. That we stop any consent-based processing of your personal data after you withdraw that consent. Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
6. Review by a ZDHC team member of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
7. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

You always have the right to request a copy of any information about you that ZDHC holds at any time, and to have that information corrected if it is inaccurate. 

To ask for your information or request it to be amended, please email media@zdhc.org, or update the setting in your online account.

If we choose not to action your request we will explain to you the reasons for our refusal.

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make pursuant to this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

There are several ways you can stop receiving direct communications e.g. our newsletters from us:

• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from us.
• If you have an account, log in into your ZDHC account, visit the ‘My Account’ area and change your preferences.
• Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated

Finally, if you feel that your personal data has not been handled correctly by ZDHC, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Dutch Data Protection Authority (Dutch DPA):

Postal address

Autoriteit Persoonsgegevens

Postbus 93374

2509 AJ DEN HAAG

Telephone number: (+31) (0)70 888 85 00

Fax: (+31) (0)70 888 85 01  

If you are based outside the Netherlands, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. 

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

Email us at media@zdhc.org

Or write to us at ZDHC Foundation, Watersteeg 3, 1012 NV Amsterdam, the Netherlands