THE EUROPEAN FUEL MANUFACTURERS ASSOCIATION

PRIVACY NOTICE FOR MEMBER COMPANIES' REPRESENTATIVES AND NOIA REPRESENTATIVES AND OTHER EXTRANET USERS

The European Fuel Manufacturers Association AISBL, acting through its Concawe and FuelsEurope divisions ("We", "us", "our"), is committed to complying with EU Privacy Law. This privacy notice (the "Notice") describes how We process the Personal Data We collect from designated representatives of our members and National Oil Industry Associations ("NOIA") representatives and other Extranet Users ("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 collect about You?

The personal data We collect about You are:

(a)             First Name and Last Name;

(b)             Email address;

(c)             If you are an officer of the association (director, alternate director, treasurer, president or vice-president), a copy of your ID card or passport;

(d)             Name of the organization you belong to;

(e)             Function within the organization;

(f)              Your professional fixed and/ or mobile phone number; and

(g)             If you are a director or alternate director, or the chair of a working group, the information in your CV.

All together your "Personal Data"

We typically collect Personal Data directly from You or from the organization You belong by email or fax (in such case under the assumption that specific measures have been put in place by such organizations to lawfully provide us with your Personal Data). 

2.               How do We collect and process (use) your Personal Data? And on which legal basis?

We use your Personal Data for different purposes. These include:

(a)             Organizing and handling general assemblies and board meetings (including power of attorneys for proxy voting procedures);

(b)             Keeping records of the board meetings and the general assembly and circulating minutes;

(c)             Publishing relevant resolutions such as the appointment, renewal or replacement of directors in the Belgian official journal;

(d)             If you are the director general, the president or treasurer of the association, submitting beneficial ownership and related mandatory declarations (Déclaration bénéficiaire effectif).

We do so in order to comply with our legal obligations under Belgian laws.

We also process your Personal Data in order to run the operations of the association and provide You with the associated benefits of your membership.

In particular, We process your Personal Data to: 

(a)             Administer your organization's membership;

(b)             Keep membership records;

(c)             Process membership fees' payments;

(d)             Send out surveys, voting papers and other information relevant to our functions and obligations;

(e)             Establish and maintain communications with You;

(f)              Provide content or services You request from us;

(g)             Invite You to attend our committees, working groups and task forces and run such committees, working groups and task forces;

(h)             Send You our publications, brochures, newsletters, reports and other materials;

(i)              Invite You to our events, conferences and workshops;

(j)              Publish your contact details on Sharepoint in order for our members to be able to know who is participating in the different working groups and be able to work on cross-border matters;

(k)             Manage complaints and conduct investigations and disciplinary or dispute resolution activities.

We do so based on our legitimate interest (or, for cases referred under (b), (c), and (k) above, in order to comply with legal obligations under Belgian laws). As a trade association, we have the interest in carrying out the activities necessary to perform the purpose ascribed in our statutes and operating guidelines. In doing so, we considered your rights and expectations as a Data Subject and have assessed that your interest, fundamental rights and freedoms are not put at risks. When we collect and process your Personal Data based on legitimate interest, You have specific rights (see s8 below for more information in that regard).

When You register to our events, webcasts, seminars, etc., You will receive a specific privacy notice.

3.               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 (as well as your rights in relation to such further processing).

4.               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.

We may, should the need arise, share your Personal Data with:

(a)             IT service providers;

(b)             Travel agencies;

(c)             Where necessary and appropriate with our counsel (who is bound by professional secrecy rules) or financial institutions.

In order to send You our newsletter and reports, We share your Personal Data with MailChimp (https://mailchimp.com/), a third party providing email marketing services. MailChimp is located in the United States. Your Personal Data are transferred to, stored and processed in the United States and may be shared there. We have taken steps with MailChimp to ensure that the transfer of your Personal Data to MailChimp complies with EU Privacy Law. MailChimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We have also signed a Data Processing Agreement incorporating Standard Contractual Clauses with MailChimp. If You would like to receive a copy of the agreement, You can contact us at privacy@fuelmanufacturers.eu.

We do not use other third-parties to process your Personal Data or otherwise transfer Personal Data outside of the EEA and/or disclose your Personal Data to other recipients than those identified in this Notice. If we were to do so, We will comply with EU Privacy Law.

5.               Data security

Your Personal Data are treated as confidential.

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 update and test our security technology on an ongoing basis. We restrict access to Your Personal Data to those employees and staff who need to know that information to provide benefits or services to You. In addition, We train our staff about the importance of confidentiality and maintaining the privacy and security of Your information. We commit to taking appropriate disciplinary measures to enforce our staff' privacy responsibilities.

6.               How long will We retain your Personal Data?

We retain your Personal Data in accordance with our retention policy. As a general principle, We keep your Personal Data only as long as it is necessary or legally required.

7.               "Cookies" and Internet tags

We process information about visits to our websites, the web pages visited, the date and time that you view our website and what you clicked on, your IP address, the geographical location from which you accessed our website based on your IP address, information about your computer or device (device and browser type). Such information includes Personal Data. We use this information for internal purposes to compile aggregate statistical data about users' browsing actions and patterns and to estimate our audience size and usage patterns. We obtain information by installing technical "cookies" to capture session data.

8.               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 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 information where there is no good reasons 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 there is something about your particular situation which makes You want to object to the 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 (data portability).

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 Supervisory Authority.

 

9.               How can You contact us?

For more information, or if You have questions about your Personal Data, on the way We collect and process Personal Data, or want to exercise any of your rights under this Notice, You can contact the association's Legal Advisor at +32 2 566 91 22 or the Finance s Manager at +32 2 566 91 18. You can also contact the association via email at privacy@fuelmanufacturers.eu

10.            Changes to Notice

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

11.            Our contact details

European Fuel Manufacturers Association AISBL

FuelsEurope / Concawe

Boulevard du Souverain 165 - 3rd floor, 1060 Brussels, Belgium

Tel. +32 2 566 91 00

Fax. +32 2 566 91 11

Email: privacy@fuelmanufacturers.eu

12.            Glossary

 

In this Notice:

"Data Processing Agreement" means the agreement that sets out BSEF and MailChimp's responsibility in line with Article 28 GDPR (or any other similar agreement to be entered in due course by us in accordance with EU Privacy Law).

"Data Subject" means an identified or identifiable individual.

"EU Privacy Law" means the General Data Protection Regulation 2016/679 ("GDPR") and the Belgian national privacy laws, as amended from time to time.

"EU-US Privacy Shield Framework" means the framework designed by the EU Commission and the US Department of Commerce allowing organisations located in the EU to transfer personal data to US companies certified under the framework.

"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.

 

"Standard Contractual Clauses" means the clauses adopted by the EU Commission to allow the transfer of personal data (as defined under EU Privacy Law) outside of the European Union.

 

Last update: June 2022