Starting May 25, 2018 GDPR compliance is required if you are collecting data across Europe. Read what CMNTY did to ensure GDPR compliance.
Part of our compliance roll-out, we have added a Privacy Statement so you can inform your members of how you will use member data. The below statement is a template and should be completed with relevant information regarding how you will use your community’s data.
Within the template, we have identified required information, “«»”, in bold and considerations “<>” in italics. Our statement is a guideline and you can use any privacy statement you please on your platform.
Disclaimer: We offer this Privacy Statement Template as a service. It comes without warranties. Please check with your compliance team or security officer to make sure your privacy statement is accurate.
Privacy Statement Template
PRIVACY STATEMENT «Company full name»
Last updated: «Date»
This is the Privacy Statement of «Company full name». (hereinafter: ‘«Company short name»’, ‘we’, ‘us’ or ‘our’). This statement explains how we deal with personal information that is obtained via our platform available at «URL» (hereinafter: ‘Platform’). We respect the privacy of our users and ensure that any personal information we receive will be protected and treated confidentially.
COLLECTION AND USE OF PERSONAL DATA
If you subscribe at our Platform, you will provide us with certain personal information that can be used to identify you, such as: «name the information you request (eg: first name, last name)»
We use this information to provide you with information about what is happening on the Platform or with other members on the Platform. In addition, we may use this information to <send you information about our products, respond to your requests, promote our Services, award credits and give discounts in our web shop.>
<Some parts of this information are considered to be sensitive personal data. This information is only collected by us with your explicit consent.>
<We may also use anonymized or pseudonymized information for analysis purposes. Anonymization means it will no longer be able to identify you based on the information we use for our analysis.>
<We may also use collected personal information for analysis purposes.>
We will not provide your personal information to other users or third parties except as described below:
Information disclosed to third parties?
The data you provide is processed by CMNTY Corporation as the provider of this Platform.
Information disclosed for our protection and the protection of others
We may cooperate with government and law enforcement officials or private parties to enforce and comply with applicable laws and regulations. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our (intellectual) property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
Information disclosed and potential business transfers
Information that we collect from you as a user, including personal information, is considered to be a business asset and will be treated accordingly.
USER RIGHTS (Inspection, Correction, Resistance and Removal)
You have the right to request us free of charge, rectification and erasure of your personal data by sending an e-mail to «Email address». This same email address can also be used to object to the processing of your personal data. When you send us such a request we may, as a security measure, request you to send a copy of your identity document, whereupon your BSN number is made illegible.
Apart from the above, you can always get an overview of your own personal details and personal settings and adjust them if necessary by logging in and adjusting your account settings.
If we fail to comply with one of the aforementioned requests, you have the right to file a complaint with the Dutch Data Protection Authority or lodge an appeal with the court.
You have the right to obtain the personal data you have provided to us, in a structured, current and machine-readable form, if you would wish to transfer them to another party.
We offer a newsletter in which we inform our users about our products and / or services. On registration you can opt-in for this newsletter. Each newsletter contains a link with which you can unsubscribe yourself.>
INTERNATIONAL DATA TRANSFER
<The information Google collects (see section COOKIES AND GOOGLE ANALYTICS) is anonymised as much as possible. The information is transferred to and stored by Google on servers in the United States. Google states that the SafeHarbor principles it follows are in line with the SafeHarbor program of the US Department of Commerce.>
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your personal and organisation information) from unauthorized access, use or disclosure.
Please be aware that the security of your personal and organisational information also depends on the protection of your account. Do not disclose your website login credentials to unauthorized people. Also, be sure to sign off when finished using a shared computer.
COOKIES AND GOOGLE ANALYTICS
We have implemented the following Google cookies:
- Google Display Network Impression Reporting
- Demographics and Interests Reporting
- DoubleClick DART Cookies
You may opt-out of the use of DART cookies by visiting the Google Ad and Content Network privacy statement. Other cookie settings can be regulated in your browser. However, the exact procedure differs per browser. We recommend that you follow the instructions and/or use the help function of your browser to change the desired cookie settings. Please note that in some cases you may not be able to use all functions of our Platform, when using more strict cookie settings.
We honour do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
HYPERLINKS OF THIRD PARTIES
This Platform may contain links to third party websites. This Privacy and Cookie Statement does not apply to websites of third parties and «Company short name» accepts no liability with regard to the way in which these third parties handle your personal data. We therefore advise you to consult the privacy statement of all websites you visit.
CHANGES TO THIS STATEMENT
Any information collected via our Platform is covered by this Privacy Statement. We may revise this statement from time to time. If we make a change to this Privacy Statement that, in our sole discretion, is material, we will try to notify you of those changes by posting them on our Platform and/or by sending you an email to the email address associated with your account and we will update the “Last Updated Date” above to indicate when those changes will become effective. By continuing to access or use our Platform after those changes become effective, you agree to be bound by the revised Privacy Statement.
QUESTIONS AND CONTACT
If you have any questions or remarks, please contact us via: «Email address», <or contact our data protection officer by sending an email to: «Email address»>.
«Company short name» is registered at the Chamber of Commerce under the following registration number: «Chamber of commerce number».
All content and data used should be outlined in the Privacy Statement. It is important to be as thorough with these statements to prevent liability. Please outline any other processors that might process the data from your platform. Any servers that are outside the EU should noted in this statement.
If you have any questions, please reach out to firstname.lastname@example.org.