Together for Sustainability AISBL

Together for Sustainability AISBL ("We", "TfS" "us", "our"), is committed to complying with EU Privacy Law. This privacy notice (the "Notice") describes how We process the Personal Data (as defined below) We collect from visitors of our website, subscribers and recipients of our newsletter and individuals who download our reports ("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.

1. What Personal Data do We hold about You and Why?

We collect Personal Data from You:

(a) When You download our TfS reports – We ask You to provide us with your email address, the name of the organization You work with and your function within the organization. 

(b) When You are part of the TfS community - We process your email address and the name of your organization to share our newsletter with You. 

(c) When You subscribe to our newsletter – We collect your name, your email address, the name of the organization You work with and We also give You the option to specify your job title and department. 

(d) Through the use of cookies and other tracking technologies – Please refer to s.3 below to know more on our use of cookies.

2. Why do We collect your Personal Data and on which legal basis?

(a) When You download our reports:

• We ask the above Personal Data in order to be able to understand our audience and improve our services. We do so based upon our legitimate interest. Indeed, it is important for us to know who has an interest in our reports. 

(b) When You subscribe to our newsletter or if You receive it: 

• If You are part of the TfS community, We rely on our legitimate interest in order to share our newsletter with You. We do so because You are part of our community and We want You to be informed about our activities that are of interest to You and benefit from our services.

∑   If You are not part of the TfS community and You subscribe to our newsletter, We do so based on your consent. 

When We rely on our legitimate interest, We consider your rights and expectations as a Data Subject and assess that your interest, fundamental rights and freedoms are not put at risk. 

You have specific rights (see s. 8 below for more information in that regard).

3. Our use of cookies 

We use online identification technologies such as cookies on our website. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. 

The information We collect through the use of Cookies includes Personal Data (such as your IP address). To know more about our use of cookies, please open our Cookie Details and Preferences. Following the mentioned link You can also set up or change your cookies’ preferences at any time. Alternatively, the following website provide some useful information on how to do this: www.allaboutcookies.org.

You can also take proactive steps yourself, for example, to opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout for more information.

You can finally find out how to manage Cookies on popular bowsers using the links below:

(a) Google Chrome
(b) Mozilla Firefox
(c) Microsoft Internet Explorer
(d) Apple Safari

Essential cookies are required to enable core website functionality; therefore You cannot opt-out from their use.

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. Which third-parties process your Personal Data? Do We Share, Disclose or Transfer Personal Data?

In order to conduct our activities, We may have to share or disclose your Personal Data with third parties, including third-party service providers.

In particular, We share your Personal Data with:

(a) IT experts who provide services to TfS office (e.g., data storage or website administration)
(b) Mailchimp, the platform We use to send You our newsletter. 
(c) Third-parties that set cookies on your device, as identified in “Cookie Details and Preferences” [link to be included].

Some of the third-parties We share your Personal Data with are based outside the EEA. When We transfer Personal Data outside the EEA, We comply with EU Privacy Law and put safeguards in place. If You would like to know more about the measures We take to protect your Personal Data, You can contact us at info@tfs-initiative.com.

6. Data security

Your Personal Data are treated as confidential. 

We never pass on your contact details to third-parties for commercial purposes. 

In order to safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, We have put in place appropriate administrative, physical and technical measures. We restrict access to your Personal Data to those employees and staff who need to know that information. In addition, We train our staff about the importance of confidentiality and maintaining the privacy and security of your information.

7. How long will We retain your Personal Data?

We retain your Personal Data in accordance with our Retention/Destruction Procedures and Policy. As a general principle, We keep your Personal Data only as long as it is necessary or as long as You don't object to the Processing.

8. Your rights in connection with Personal Data

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

(a) 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.

(b) 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.

(c) Request erasure of your Personal Data. This enables You to ask us to delete or remove Personal Data where there is no good reason 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).

(d) 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.

(e) Request the transfer of your Personal Data to another party (right to data portability). 

When We process your Personal Data based on our legitimate interest (or those of a third-party), You have the right to object to such Processing. 

When We rely on your consent, You have the write to withdraw it at any time by clicking on the unsubscribe button at the bottom of our newsletter.  

To exercise your rights as Data Subject, make queries or complaints, please contact:info@tfs-initiative.com.

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 relevant Supervisory Authority.

9. How can You contact us?

For more information, or if You have questions about your Personal Data, or on the way We collect and process Personal Data, or want to exercise any of your rights under this Notice, You can e-mail us at:info@tfs-initiative.com.

10. Effect of Notice and changes to Notice

We may revise this Notice from time to time and any revisions will be made available to You via our website.

11. Our contact details 

Together for Sustainability AISBL (TfS)
Rue Belliard 40, bte 20
1040 Brussels
Belgium
E: info@tfs-initiative.com
T: +32 2436 9620

12. 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.

"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. 2
February 2021