THE VALE
Privacy Policy
The VALE Privacy Policy
The VALE cares about your privacy and about protecting the Personal Data handled by us. All Personal Data is Processed in accordance with Applicable Law. In this policy, we describe how and for what purposes we use your personal information as well as the legal basis and measures we take to protect Personal Data. We also provide information on how you exercise your rights linked to our use of your Personal Data.
WHY AND WHO
The VALE (“The VALE Team”, “we”, “us”, “our”) is the Controller of all Personal Data listed in this Privacy Policy (the “Policy”). In order to be fully transparent regarding where your Personal Data is stored and Processed, we provide a list of all our data Processors.
DEFINITIONS
“Applicable Law” refers to the legislation applicable to the processing of Personal Data, including the GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by a national or EU supervisory authority.
“Controller” is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
“Data Subject” is the living, natural person whose Personal Data is being processed.
“Personal Data” is all information relating, directly or indirectly, to an identifiable natural person.
“Processing” means any operation or set of operations which is performed on Personal data, e.g. storage, modification, reading, handover and similar.
“Processor” is the company/organisation that processes personal data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
THE VALE’S PROCESSING OF PERSONAL DATA
We have a responsibility to describe and demonstrate how we fulfill the requirements that are imposed on us when we process your Personal Data. This section aims to describe:
- That processing of Personal Data is necessary for the purpose
- That we have identified the lawful basis for the processing
Lawful basis
Consent – The VALE may process personal data if the data subject has given explicit consent in that specific data being processed for a specific purpose. Consent must be freely given, specific, informed and unambiguous, and can be withdrawn at any time.
Legitimate interest – The VALE may process personal data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the data subject, and if the processing is necessary for the purpose in question.
PROCESSINGS
- PARTICIPANT APPLICATION
- Purpose of processing
For the admissions team to review the body of applicants in order to make a final selection of participants as well as being able to share future relevant opportunities (courses, events, webinars, etc.). - Personal data
Name, place of residence, email, YFU organization, nationality, birthday, phone number, dietary restrictions, freely given information about applicants’ experiences and background, vaccination status. - Who has access to it
The VALE Team. In addition, name and email might be shared with Partner Organizations in order to consult on the selection process of applicants from their own organizations (and only on those). - Lawful basis
Legitimate interest. - Storage period
Three years after the project has been finalized.
- Purpose of processing
- ADDITIONAL PARTICIPANT INFORMATION
- Purpose of processing
Coordinating travel logistics and reimbursements, as well as ensuring health and safety at on-location. - Personal data
Dietary restrictions, address, passport information, banking information, emergency contact and critical health information that requires The VALE Team to take specific measures for the participation of this person. - Who has access to it
The VALE Team. - Lawful basis
Legitimate interest. - Storage period
Duration of the project.
- Purpose of processing
- THE VALE TEAM – LOGISTICAL INFORMATION
- Purpose of processing
Processing personal data about The VALE Team members in order to carry out project coordination, travel logistics, reimbursements and to ensure health and safety. - Personal data
Name, birthdays, YFU organization, nationality, place of residence, phone number, emails, dietary restrictions, virtual call user names, banking information and vaccination status. - Who has access to it
The VALE Team. - Lawful basis
Legitimate interest. - Storage period
Two years after the project has been finalized.
- Purpose of processing
- THE VALE TEAM – EXTERNAL COMMUNICATION
- Purpose of processing
Processing personal data about The VALE Team members in order to promote and communicate about the course in external communication channels. - Personal data
Name, nationality, pictures, video, information about experiences and background. - Who has access to it
Publically available through The VALE’s website and social media channels. - Lawful basis
Legitimate interest. - Storage period
Indefinitely.
- Purpose of processing
- EMAIL
- Purpose of processing
Communication with partners, collaborators, venues, participants and team members in order to facilitate the logistics and coordination of the project. - Personal data
Name, email address, job position and other information that might arise in the communication. - Who has access to it
The VALE Team. - Lawful basis
Legitimate interest. - Storage period
10 years.
- Purpose of processing
- PHOTO AND VIDEO CONFIRMATION
- Purpose of processing
To archive the course experience and memories for the participants, to communicate to the external world what we do, as well as to market future projects by The VALE. - Personal data
Name, nationality, pictures, video and personal testimonials. - Who has access to it
Publicly available through The VALE’s website and social media channels. - Lawful basis
Consent. - Storage period
Indefinitely.
- Purpose of processing
- GUEST SPEAKERS/ TRAINERS – LOGISTICAL INFORMATION
- Purpose of processing
Coordinating travel logistics and reimbursements, as well as ensuring health and safety at the venues. - Personal data
Name, nationality, banking information and dietary restrictions. - Who has access to it
The VALE Team. - Lawful basis
Legitimate interest. - Storage period
Project duration.
- Purpose of processing
- GUEST SPEAKERS/ TRAINERS – external communication
- Purpose of processing
In order to promote and communicate about the course in external communication channels. - Personal data
Name, nationality, picture, position and relevant background. - Who has access to it
Publicly available through The VALE’s website and social media channels. - Lawful basis
Legitimate interest. - Storage period
Indefinitely. - WEBINARS & ONLINE EVENTS
- Purpose of processing
In order to facilitate the organizing of the event as well as being able to share future relevant opportunities (courses, events, webinars, etc.). - Personal data
Name, nationality, email, connection to YFU - Who has access to it
The VALE Team and event co-organizers - Lawful basis
Legitimate interest. - Storage period
Three years after finalization of event.
YOUR RIGHTS
You are the one in control of your Personal data, and we strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access – You always have the right to receive information about the Processing of data that concerns you. We only provide information after having verified your identity to ensure that it is indeed you that are requesting the information.
Rectification – If you find that the Personal Data we process about you is incorrect, let us know, and we will fix it!
Erasure – Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections – Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry – in such cases, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data.
Withdraw consent – If you have given consent to one or several specific processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future processing of Personal Data and not for Processing that has already taken place.
How you use your rights
Contact us at contact@thevale.eu and we will help you.
THIRD-PARTY PROCESSORS
- Processor: Google (Google Drive)
Justification: We use Google Drive for documentation purposes, including handling of all data in the aforementioned processings. - Processor: STRATO Webmail
Justification: We use STRATO Webmail as an email provider. - Processor: The VALE Partner Organizations (YFU Austria, YFU Czech Republic, YFU Denmark, YFU Estonia, YFU Finland, YFU Germany, YFU Italy, YFU Latvia, YFU Lithuania, YFU Norway, YFU Romania, YFU Turkey, EEE-YFU).
Justification: Partner organizations who have signed on the Erasmus+ grant partnership agreement with whom we will share relevant participant information only pertaining to their organization.
CHANGES TO THIS POLICY
We reserve the right to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.
CONTACT
Please contact us if you have questions about your rights or if you have any other questions about how we process your personal information:
contact@thevale.eu
or use the contact form below.