1. WHO WE ARE
“We”, “us”, “our” or “ELP Network” means ELP Network Advisory Services CV with registered office at Sluisstraat 79, 3000 Leuven, Belgium and with company number BE 0687.891.231 and “ELP” means Executive Learning Partnership CV with registered office at Sluisstraat 79, 3000 Leuven, Belgium and with company number BE 0475.802.321.
We act as a controller for (i)the personal data we gather of you through the use of our Website: https://www.elpnetwork.com (“Website”) and (ii)the personal data we collect about you in relation to our services, such as when you’d participate in a conference, a training programme, a workshop or embark on a coaching programme with us (“Services”).
Your privacy is a priority at ELP Network, that is why we’ve developed this privacy policy that sets out how we collect, disclose, transfer and use (“Process”) the personal data that you share with us, and how we‘ll be respecting your rights in accordance with the objectives and obligations arising from the General Data Protection Regulation, i.e. Regulation (EU) 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (‘GDPR’) and the Belgian law of 30 July 2018 on the protection of natural persons with regard to the processing of their personal data.
If you have any questions, concerns or complaints regarding this privacy policy or about how we are processing your personal or you wish to submit a request to exercise your rights as set out in article 9, you can contact us:
- via phone: +32 (0)16 241910
- via e-mail: operations@elpnetwork.com
- by post: ELP Network, Sluisstraat 79, 3000 Leuven, Belgium
2. HOW WE USE YOUR PERSONAL DATA (“PURPOSES”)
Personal data is defined as: “all information about an identified or identifiable natural person (“the Data Subject”)”. A natural person is regarded as identifiable if he or she can be identified directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more elements characterising the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.”
In the event you use an application of ELP Network, ELP Network will use and collect your personal data in accordance with its privacy policy as set out in the General Terms and Conditions of the Applications.
ELP Network will use and collect your personal data in the execution of its services for the Purposes as listed hereunder:
- to provide coaching, training and speaker services to you;
- to create tailored programmes, workshops or keynote speeches for your company and or your events;
- organising client events and conferences;
- to manage coaching or training programmes that we are contracted to deliver for you;
- to allow us to administer profiling tools or diagnostics;
- to share relevant blogs, models, training materials and ideas around leadership, business growth and performance with you;
- to verify your identity;
- for market research purposes - to better understand your needs;
- to enable ELP Network to manage client interactions with you;
- where we have a legal right or duty to use or disclose your personal data (for example in relation to an investigation by a public authority or in a legal dispute) so that we are able to enforce or exercise any rights that are available to us based on the applicable law;
- to fulfil our obligations as set out by the applicable law;
- promoting, marketing and advertising our services;
- sending promotional communications which are relevant and tailored to individual clients;
- understanding our clients’ behaviour, activities, preferences, and needs;
- improving existing services and developing new ones;
- preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
- handling client contacts, queries, complaints or disputes.
ELP Network will use and collect your personal data that is gathered through your use of our Website for the following Purposes:
- to support the Website and to enhance your user experience, which includes ensuring the security, availability, performance, capacity and health of the Website.
- in the event you use the contact form via “Contact Us” on our Website, we will use your personal data in order to reply to your query, via e-mail or phone.
- in the event you subscribe via the Website to get our latest insights, we will use your e-mail address in order to send you our latest insights in the form of newsletters, which may include invites to events, seminars etc…
- in the event you’d would like to know more about our practices and you use the contact form on the Website, we will use your personal data in order to provide you more information about ELP Network and all of the services we can offer you.
- in the event you’d would like to subscribe to or download any of our reports, cases, insights or magazines via the form on our Website, we will use your e-mail address to provide you with said documents and some latest insights.
3. WHAT PERSONAL DATA DO WE COLLECT?
ELP Network collects the following personal data about you in the event you make use of our services:
- your name and gender;
- your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
- coaching, keynote speaker and training programme contracts agreed and signed by you;
- results that come from personality or team diagnostics;
- your communication and marketing preferences;
- your interests, preferences, feedback and survey responses;
- your location;
- your correspondence and communications with ELP Network.
ELP Network collects the following personal data that you share with us via the use of the Website:
- Your contact data (such as first name, last name, e-mail address) that is provided by you via the form “Contact Us” or if you fill in the contact data which is requested if you’d like to get our latest insights or if you’d like to know more about our practices or if you want to download report, cases, insights or magazines. We also collect the personal data you provide to us via the therefore designated blank field on the Website. Please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions or credit card/account numbers.
- Your usage data, such as IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of the visit, page views or information about timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our Website. In the event the usage data is completely anonymised (and can therefore not be traced back to you as an individual) this will not be considered personal data for the purpose of this privacy policy. This is personal data that is automatically collected through your use of our Website.
We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
4. THE LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA (“LEGAL BASIS”)
The Legal Basis for the processing your personal data by ELP Network in the event you make use of our Services, is the necessity for the performance of a contract you’ve concluded with us. We need your contact details, name and agreed and signed contracts, as well as the results that come from personality or team diagnostics in order to be able to execute the contract.
The legal basis for the processing of the other personal data we collect of you in the event you make use of our Services and our Website is our legitimate interest, namely to provide you with a useable Website and to communicate with you in relation to your queries and concerns.
In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to future clients via email or LinkedIn and to promote and advertise our Services to future clients. In the event you are an existing client of ELP Network, and the direct marketing communication relates to the Services you receive, the legal basis for the processing is ELP Network’s legitimate interest.
You have the right to opt-out of receiving any such promotional communications at any time, by:
- making use of the simple “unsubscribe” link in emails; or
- contacting ELP Network via the contact channels set out at the beginning of this Policy.
We may analyse your responses to any marketing communications. The results of this analysis, together with other demographic data, allows us to ensure that we contact you with information that is relevant to you.
In the event the legal basis for the processing is consent, you have the right to withdraw your consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn. This will however not affect the lawfulness of any processing done prior to the withdrawal of your consent.
In the event the legal basis for the processing is our legitimate interest you will have the right to object to such processing, as set out in article 9 of this privacy policy.
5. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
OUR SERVICE PROVIDERS AND SUPPLIERS
In order to make certain Services available to you and to provide you with our Website and certain applications we use, we share your personal data with our Service partners. These include IT service providers, service providers for the hosting of our Website, associates and marketing service providers.
ELP Network only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on our service providers relating to data protection and security, which mean that they can only use your personal data to provide services to ELP Network and to you in accordance with the purposes as set out in this privacy policy, and for no other purposes.
OTHER THIRD PARTIES
Aside from our service providers, ELP Network will not disclose your personal data to any other third party, except as set out below. We will never sell or rent your personal data to other organisations for marketing purposes. We may share your personal data with governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are legally required to do so:
- to comply with our legal obligations;
- to exercise our legal rights (for example in court cases);
- for the prevention, detection, investigation of crime or prosecution of offenders;
- for the protection of our employees, associates and clients.
As such, we do not disclose your personal data to our social media partners. We do, however, make use of the social media plugin of LinkedIn to direct you to our LinkedIn and to allow you to interact with our content. In the event you click on the link, LinkedIn may collect personal data about you and may link this information to your existing profile on LinkedIn.
For the avoidance of doubt, we are not responsible for the use of your personal data by LinkedIn. In such case, LinkedIn will act as the controller of your personal data.
6. INTERNATIONAL TRANSFERS
To deliver our Website, our products and Services to you, it is sometimes necessary for ELP Network to share your personal data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use the ‘Standard Contractual Clauses’ which have been approved by the European Commission for such transfers.
7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will not retain your personal data for longer than necessary for the purposes as set out in this privacy policy. The retention period for personal data is 3 years.
In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.
The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.
8. YOUR RIGHTS
This article lists your principal rights under data protection law. We have tried to summarise them for you in a clear and legible way.
To exercise any of your rights, please send us a written request in accordance with article 1 of this privacy policy including proof of your identity by attaching a copy of the front of your identity card to your request. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond, or in the event we do not take action on your request, we will notify you.
RIGHT OF INSPECTION AND TO ACCESS
You have the right to confirmation as to whether or not we process your personal data. In the event we do so, you have the right to access your personal data and to check how your personal data is being used.
You may obtain a free copy of your available personal data at any time by simply making a request to this effect, providing that this does not adversely affect the rights and freedoms of others.
RIGHT TO CORRECTION
If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.
RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)
In the following circumstances, you have the right to have your personal data erased:
The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
- You withdraw your consent, and no other lawful ground exists;
- The processing is for direct marketing purposes;
- The personal data have been unlawfully processed; or,
- Erasure is necessary for compliance with EU law or Belgian law.
There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation; or,
- for the establishment, exercise or defense of legal claims.
RIGHT TO RESTRICT PROCESSING
You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:
- You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
- The processing is unlawful, and you request restriction (as opposed to exercising the right to erasure);
- We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
- You have objected to processing, pending the verification of that objection.
In addition to our right to store your personal data, we may still otherwise process it but only:
- with your consent;
- for the establishment, exercise or defense of legal claims;
- for the protection of the rights of another natural or legal person; or,
- for reasons of important public interest.
RIGHT TO OBJECT
You may oppose the processing of your personal data at any time if your objection is based on serious and legitimate reasons, and only to the extent that the legal basis for the processing is that the processing is necessary for (i)the performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or (ii)the purpose of the legitimate interest pursued by us or by a third party.
If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
If you wish to oppose the use of your personal data for direct marketing purposes (which is only possible if we are processing your personal data on the legal ground “legitimate interest” see article 4 of this privacy policy), you do not have to give any reasons for this. We will cease to process your personal data for this purpose.
RIGHT TO WITHDRAW CONSENT
If the processing of your personal data is based on consent you have given, you may withdraw this consent at any time.
RIGHT TO DATA PORTABILITY
Under the conditions stipulated in the GDPR, you have the right to obtain your personal data in a structured, commonly used and machine-readable form. You may ask ELP Network to transfer your personal data in this way to another controller. For the avoidance of doubt, you only have this right to the extent that the legal basis for the processing is that (i)the processing is based on your consent or (ii)the processing is carried out by automated means.
THE RIGHT TO COMPLAINT TO A SUPERVISORY AUTHORITY
If you believe that your rights as a data subject are being infringed by us you have the right to make a complaint to the supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to the Data Protection Authority (the Data Protection Authority, Drukpersstraat 35, 1000 Brussels, email: contact@apd-gba.be, tel. +32 (0)2 274 48 00, fax +32 (0)2 274 48 35), without prejudice to any other possibility of initiating a judicial review or seeking a judicial remedy.
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