THE EUROPEAN
FUEL MANUFACTURERS ASSOCIATION
SIEF PRIVACY NOTICE
This SIEF privacy notice (this "Notice") explains how the European Fuel Manufacturers Association AISBL, acting
through its Concawe division ("Concawe", "We", "us",
"our") processes information in connection with Concawe’s
role as SIEF/post SIEF facilitator for petroleum substances in compliance with
the EU General Data Protection Regulation ("GDPR").
1.
What Personal Data do We hold
about You?
We collect, store and use the following categories of Personal Data
about You:
(a)
If you are the
authorised representative and/or contact person, your name, organization, job
title, email address, business address and telephone number (mobile and/or
fixed line); and
(b)
Organization
billing information.
2.
How is
your Personal Data collected?
We
collect Personal Data about You through our SIEF webpage or when You contact us
by mail. Personal Data are provided to us voluntarily by You directly or via a
third party authorized by You to disclose your Personal Data to us.
3.
Why do We use your Personal Data?
We
process your Personal Data for the following purposes:
(a)
Processing web
order links;
(b)
Preparing licenses,
SIEF collaboration services or lead registrant agreements;
(c)
Performing
obligations in the course of or in connection with our provision of the license
or SIEF collaboration services;
(d)
Responding to
queries, requests, complaints and feedback from You;
(e)
Processing
invoices/billing, payment and accounting operations;
(f)
Data collection for
the maintenance or update of the REACH dossier for the considered substance;
(g)
IT maintenance and
update of IT tools;
(h)
Complying with any
applicable laws, regulations, codes of practice, guidelines or rules;
(i)
Sending You our
communication with regard to REACH registration dossier, dossier updates, fees
or other matters relating to the license or SIEF collaboration services
agreement.
4.
On which
legal basis do We rely to process your Personal Data?
We will
rely on the following legal basis with regard to the purposes identified above:
|
Purpose of processing |
Lawful basis for processing |
|
Processing web order links |
Performance of a
contract |
|
Preparing licenses, SIEF
collaboration services or lead registrant agreements |
|
|
Performing obligations
in the course of or in connection with our provision of the license or SIEF
collaboration services |
|
|
Sending
you our communication with regard to REACH registration dossier, dossier
updates, fees or other matters relating to the license or SIEF collaboration
services agreement and other SIEF information |
|
|
IT maintenance and
update of IT tools |
|
|
Responding to queries,
requests, complaints and feedback from You |
|
|
Processing
invoices/billing, payment and accounting operations |
|
|
Data collection for REACH dossiers |
Legal obligation |
|
Complying with any
applicable laws, regulations, codes of practice, guidelines or rules |
5.
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.
6.
Which third-parties process your Personal
Data? Do We share, disclose or transfer Personal Data
We may have to share or disclose your Personal Data
to third parties, including third-party service providers.
We disclose your Personal Data when such disclosure is
required for performing obligations in connection with the license or SIEF
(post SIEF) collaboration services, for instance when requesting IT to fix
technical issues with a web order or when requesting external accounting
personnel to fix issues in the accounting system.
We share your Personal Data with third party IT and accounting service
providers, agents and other organizations We have engaged to perform any of the
purposes identified above. Any such third party service provider engaged by us is expected to comply with the
requirements of the GDPR and this Notice.
7.
Data security
Your Personal Data are treated as confidential. We
never pass on your Personal Data 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 such as antivirus protection and encryption to
secure all storage and transmission of Personal Data by us, and disclosing
Personal Data both internally and to our authorized third party service
providers and agents only on a need-to-know basis. You should be aware,
however, that no method of transmission over the Internet or method of electronic
storage is completely secure. While security cannot be guaranteed, We strive to
protect the security of your information and are constantly reviewing and
enhancing our information security measures.
8.
How long will We retain your Personal Data?
We store your Personal Data for the duration of the licence agreement,
SIEF collaboration services agreement or lead registrant agreement. We commit
to delete the Personal Data We hold about You upon termination of the licence
agreement, SIEF collaboration services agreement or lead registrant agreement,
unless other requirements apply based on our retention policies or under EU or
national laws.
When We process your Personal Data based on
your consent or on our legitimate interest, We store your Personal Data as long
as You don't withdraw your consent or don't object to the Processing. In these
cases, We undertake, absent of any Processing activities within a period of 24
months, to delete the Personal Data We hold on You. However, We may retain your
Personal Data under EU or national laws.
We may retain electronic copies of files
containing Personal Data created pursuant to automatic archiving or back-up
procedures which cannot reasonably be deleted. In these cases, We shall ensure
that the Personal Data are not further actively processed.
9.
Your rights in connection with your 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 information 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)
Object to processing of your Personal Data
where We are relying on a legitimate interest (or those of a third party) and
You want to object to processing on this ground.
(e)
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.
(f)
Request the transfer of your Personal Data
to another party (right to data portability).
10.
How can You contact us?
For more information, or if You have questions about your Persona Data,
on the way We collect and process Personal Data, or want to exercise your rights as data subject, make queries
or complaints, please contact our Legal Advisor at +32 2 566 91 22 or the REACH
SIEF Manager at +32 2 566 91 07. You can also contact us via email privacy@fuelmanufacturers.eu. or visit
us at our office at 165 Boulevard du Souverain, 1160 Brussels, Belgium.
11.
Changes To Notice
We may revise this Notice from time to time and any revisions will be made available to
You via the SIEF space.
12.
Glossary
In this Notice:
"Personal Data"
means any information
about an individual from which that person can be identified.
"You" or "Data Subject" means an individual:
(a)
Who has contacted
us through any means to find out more about the REACH Licenses or the SIEF (and
post SIEF) collaboration services We provide; or
(b)
Whose organization
has entered into a License agreement, SIEF Collaboration Services or Lead
Registrant contract with us.
"Processing" means any operation or
set of operations which is performed upon Personal Data, whether or not 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.
Other terms used in this Notice shall have the meanings given to them in
the GDPR or the REACH Regulation (where the context so permits).
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Last update: June 2022