Privacy Policy 

 

The Irish Thai Chamber of Commercetake your privacy seriously. We updated our 

Privacy Policy to increase transparency and to reflect updates to how and why we handle your personal data.  

These updates include: 

• We explain that we may need to ask for additional personal information to authenticate certain online payments. 

• We made revisions for clarity around how we use the information we collect from you.  

• We explain how we may share your information with our parent company, Personify, Inc. 

• We explain how we may share your information with third-party service providers, including electronic payment vendors. 

 

Effective Date: June 27, 2019 

Your privacy is important to the Irish Thai Chamber of Commerce(“The Irish Thai Chamber of Commerce,” “ITCC” “us,” or “we”).  We developed this Privacy Policy to provide you with information on how we process personal data when you use our sites, mobile apps and services (hereinafter referred to as “Sites”).  

 

“Personal data” is information relating to an identified or identifiable natural person. 

 

“You” and “your” refer to the individuals reviewing this Privacy Policy, which may include The Irish Thai Chamber of Commerce members, the Irish Thai Chamber of Commerceadministers and contacts, and other individuals visiting our Sites. 

 

 

 

 

Categories of Personal Data Processed by The Irish Thai Chamber of Commerce 

 

1. Personal data that is processed when you communicate with the Irish Thai Chamber of Commerce:  When you interact with us via email, telephone, or online (e.g., when you send us an email inquiry, provide us with feedback on our services, register and post in our forums, submit support requests, and comment on blog posts), we collect personal data, including your name, organization name, phone number and email address; and information about the Irish Thai Chamber of Commerce services you have purchased.  We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue.  To improve customer service, subject to applicable laws, we may also record and review your conversations with us, and analyze any feedback provided to us through voluntary surveys concerning our customer service.  We may log in to your member account, if appropriate, to help troubleshoot and resolve your issue. 

• Purposes and Legal Grounds:  

• We use this information to provide you with support, to respond to inquiries, and to monitor and improve the quality and types of services and support we provide.  The legal ground for processing this information for these purposes is the Irish Thai Chamber of Commerce’s legitimate interest in providing quality services and support, including product and service support, such as troubleshooting support, to our customers and Site users.    

 

2. Personal data that is processed when you create an account through the Sites or seek access to a ITCC product or service (e.g., when a customer registers for a 30-day trial with ITCC):  When you conduct any of these activities, we request that you provide personal data, including your name, organization name, phone number, address, and email address.    

• Purposes and Legal Grounds:  

• Account Access.  ITCC processes your email address and password when you use your email address and your password for the purpose of enabling you to register for and log in to your ITCC account.  We use this information to identify and authenticate your identity so that you may be provided with access to your ITCC Site. The legal ground for processing your email address for this purpose is ITCC’s legitimate interest in protecting the security of your ITCC account and enabling you to access our services. 

• Account Information. ITCC also processes your contact information for the purpose of sending you information about your services or account.  The name you provide is associated with your account profile.  The legal ground for processing your contact information for these purposes is ITCC’s legitimate interest in providing you information about your services or account. 

• Requested Information. If you choose to sign up for our newsletter or any other communication from us, we will use your contact information for purposes of sending you the information you have requested. The legal ground for processing your contact information for this purpose is ITCC’s legitimate interest in providing you with the information you have requested.   

• Requested Partner Contacts. If you choose to have a partner contact you about customizing on ITCC to fit your needs, we will share your personal data (e.g., email, name, phone) with our partners for the purpose of contacting you. The legal ground for processing your personal data for this purpose is your consent, which you provide when you check the “Yes, I want a partner to contact me” box on our Sites. You may withdraw your consent at any time by contacting ITCC at contact@irishthaicc.com .If you withdraw your consent, ITCC will not share any additional personal data relating to you with its partners. Your withdrawal of consent will not apply to data that was processed prior to our receipt of your withdrawal of consent. To the extent that you provide your personal data directly to an identified third-party service provider, you should review that service provider’s privacy policy for information on its privacy practices relating to personal data. 

• Marketing Purposes. ITCC and, where permissible, our parent company, Personify, Inc., and certain third-party service providers may use your email address and other contact information for the purpose of sending you electronic marketing communications.    

• The legal ground for processing your email address and other contact information for this purpose is our legitimate interest and the legitimate interests of our parent company and our third-party service providers in sending electronic marketing communications to current and potential customers concerning products and services.  

• If you decide that you no longer wish to receive electronic marketing communications from ITCC, you will have the opportunity to opt out from receiving electronic marketing communications from ITCC at any time by clicking the preferences or unsubscribe link provided at the bottom of our marketing emails.    

• The electronic marketing communications you receive from ITCC may be based on information that you provide to us when you sign up for a ITCC account (e.g., the city/state/country in which you are located and the type of organization in which you are involved).  The legal ground for processing your personal data for this purpose is ITCC’s legitimate interest in providing its customers with information they have requested and with electronic marketing communications that are likely to be of interest to them. 

 

3. Personal data that is processed when you open a payments account or pay for products or services through our Sites or our customers’ sites:  When you pay for products and services through our Sites or our customers’ sites, we collect, but do not store, your payment information, which may include credit card data, debit card data, and Automated Clearing House (ACH) payment data, including bank name, ABA/Routing number, bank account number, account type, and account holder name. When you open a WildApricot Payments account, we collect your contact information and organization details, including Federal Tax ID, bank account details, and the SSN and Driver’s License of the organization’s authorized signer or beneficial owner.  If you pay fees to an organization with a ITCC Site or make any purchases from such an organization’s Site, you should review that organization’s privacy policy for information on its privacy practices relating to payment data and other personal data. 

• Purposes and Legal Grounds:  

• Payment Processing. When you pay for services via credit card, debit card, check, or ACH payment, ITCC will transfer your payment data (e.g.,  payment card data, bank name, ABA/Routing number, bank account number, account type, account holder name) and billing details, including recurring payment schedule if applicable, to third-party electronic payment vendors (also known as payment gateways) that process electronic payment data so that you may pay for such services. For all such payments, ITCC only transfers payment data through protected servers and does not store any payment data. If you authorize recurring payments or non-recurring future payments, your payment data and billing details will be saved by our third-party electronic payment vendors. The legal ground for processing payment data is that such processing in order to effect payment is necessary for the performance of contracts between WildApricot and our customers and between our customers and their members and contacts.  

• Choosing a Payment Processor.  When a member applies for WildApricot Payments, which is WildApricot’s own payment processing system that is powered by AffiniPay, a payment gateway that specializes in payment solutions for associations, we will share a summary of such customer’s transaction history, as well as certain customer personal data (e.g., name, SSN number, driver’s license number) with AffiniPay, who may use the information to verify eligibility for payment services, to improve the quality and speed of our services, and, where permissible, to market its payment processor services to our customers. The legal ground for processing your personal data for this purpose is your consent. You may withdraw your consent at any time by contacting WildApricot at wa.privacy@personifycorp.com. Your withdrawal of consent will not apply to data that was processed prior to our receipt of your withdrawal of consent. To the extent that you provide your personal data directly to an identified electronic payment vendor, you should review that electronic payment vendor’s privacy policy for information on its privacy practices relating to personal data. 

• Payment Authentication.  To help reduce the risk of fraud and provide added security to online payments through the adoption of 3D Secure 2.0, the industry standard approach, which also complies with Strong Customer Authentication (SCA) requirements in the European Union, WildApricot or WildApricot’s electronic payment vendors may collect additional personal data to authenticate certain online payments. For example, we may need to collect something you know (e.g., password, security question, PIN); something you have (e.g., code sent to your mobile phone or hardware token); and/or something that is unique to you (e.g., fingerprint, facial recognition). If WildApricot collects such personal data from you, we may transfer the data to our third-party electronic payment vendors who may also partner with third-party service providers to process such personal data. The legal ground for processing this data for this purpose is WildApricot’s legitimate interest in adopting an industry standard approach to reduce the risk of fraud and protect the security of your payments. 

 

4. Personal data that is processed when you provide feedback and other information in our forums: If you provide comments, suggestions, feedback, or other information in one of our forums, we will collect any personal information contained in any content you provide. Please keep in mind that whenever you voluntarily disclose personal data online in a forum accessible by others, that personal data can be collected and used by others. If you post personal data online that is accessible to the public, you may receive unsolicited messages from other parties in return. Please exercise caution whenever you post information online. 

• Purposes and Legal Grounds: ITCC processes your comments, suggestions, feedback, and other information for the purpose of providing our customers with the opportunity share such content with other customers. The legal ground for processing this information for this purpose is ITCC’s legitimate interest in enabling our customers to provide comments, suggestions, feedback, and other information they desire to share with ITCC and other ITCC members. 

 

5. Personal data that is processed when you apply for a position at ITCC:If you email us your resumé, cover letter, and LinkedIn profile to apply for an open position at ITCC, we may collect a variety of personal data, including your name, mailing address, email address, phone number, work experience, education history, references, information about your applicable degrees, licenses, and certifications, whether you are legally eligible to work in the country to which you are applying, whether you have a valid driver’s license, and your salary expectations.   

• Purposes and Legal Grounds: ITCC processes this information for the purpose of permitting you to be considered for open positions that ITCC is seeking to fill. The legal ground for processing this information for this purpose is ITCC’s legitimate interest in analyzing resume information in connection with identifying qualified candidates to fill open positions at ITCC. 

 
Third-Party Recipients of Personal Data 

• Our parent company:  We share your personal data with our parent company, Personify, Inc. Our parent company may use your data for purposes of tracking sales; contacting current and potential customers in connection with marketing ITCC and other Personify products and services; assisting current and potential customers; and for internal business purposes, such as conducting research and analysis in order to improve our products and services. 

• Third-party service providers:  We share your personal data with our service providers, who may use your personal data in connection with hosting and operating our Sites and with providing customers with requested services. Service providers who are part of our partner network may use your contact information for the purpose of marketing our products and services, as well as their products and services; and for the purpose of providing you with information that is or is likely to be useful to you, such as information you request, and information pertinent to your use of ITCC’s and our service providers’ products and services. To the extent that you provide your personal data directly to an identified third-party service provider, you should review that service provider’s privacy policy for information on its privacy practices relating to payment card data and other personal data. 

• Third-party electronic payment vendors.  We use third-party electronic payment vendors to process payment card data of our customer’s and our customer’s contacts, as well as other personal data required to authenticate certain online payments when products and services are purchased using credit or debit cards.  Additionally, when a  ITCC members applies to utilize the payment services of our electronic payment vendor, we will share a summary of such customer’s transaction history, as well as certain customer personal data (e.g., name, SSN number, driver’s license number) with our electronic payment vendor, who may use the information for purposes of account verification and, where permissible, to market its payment processor services to our customer.    

• Third parties in connection with business reorganization:  We also may transfer or provide access to your personal data to a third party in connection with an actual or impending reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of ITCC’s business or assets, including, without limitation, in connection with any bankruptcy or similar proceeding.  Any entity to which we transfer personal data will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent. 

• Governmental entities and third parties:  We may disclose personal data about you to governmental entities, such as regulatory agencies, law enforcement and judicial authorities, including to meet national security or law enforcement requirements, as well as other third parties under any of the following conditions: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, search warrant, legal process or other legal obligation; (c) to enforce any of our terms and conditions or policies; (d) as necessary in the case of emergencies or internal security matters; or (e) as necessary to pursue available legal remedies or defend legal claims. 

 
Cookies  

• We automatically collect usage data (e.g., IP address, browser details) when you interact online with our Sites through the use of cookies.  Cookies are small computer files sent or accessed from your web browser on your computer’s, mobile device’s, or tablet’s hard drive that contain information about your computer, such as user ID, user settings, browsing history, and activities conducted while using our Sites.  A Cookie typically contains the domain name (internet location) from which the Cookie originated, the “lifetime” of the Cookie (i.e., when it expires), and a randomly generated unique number or identifier. Please refer to our Cookies Policy and our Cookies - WildApricot Help page for additional information on Cookies.   

• Purposes and Legal Grounds:  We use this usage data to facilitate communication between your device and our Sites, store your preferences, authenticate users, detect and prevent fraud (e.g., fraudulent credit card use) and spam, enable certain functions of the Sites, administer and improve our Sites (e.g., troubleshoot geographically localized access problems), and analyze usage of and improve and enhance our Sites. 

• Cookie Consent:  If you are in the EU or another country that requires obtaining your consent before processing your usage data, we process your usage data based on your consent.  You may withdraw your consent at any time by contacting at contact@irishthaicc.com. Your withdrawal of consent will not apply to data that was processed prior to our receipt of your withdrawal of consent. 

• Your Control of Cookies:  To access ITCC Sites as an administrator or a customer contact, you need to enable cookies (which most web browsers do by default).  Web browsers allow some control of most cookies through browser settings. Some web browsers (including mobile web browsers) provide settings that allow you to reject cookies or that alert you when a cookie is placed on your computer, tablet, or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. 

• Third-Party Cookies:  When you visit our Sites, cookies may also be placed on your computer by third-party services that are integrated into the Site you are visiting.  For example, third-party cookies are used by Google Analytics for tracking website traffic.  We use information collected from such third-party services to help us better understand how users find and use our Sites, enhance our Sites and services, and better understand and improve users’ experience. 

 
Cross-Border Transfers of Personal Data 

Your personal data may be transferred to and stored on servers at WildApricot’s hosting provider, Amazon Web Services (AWS), in the United States.  The European Commission has recognized Canada (commercial organizations) as providing an adequate level of data protection.  The data protection and privacy laws of the United States may not be as comprehensive as the laws in your country.  For example, personal data transferred to the United States may be subject to lawful access requests by federal and state authorities in the United States.  AWS participates in the EU-U.S. Privacy Shield principles and the Swiss-U.S. Privacy Shield principles regarding the collection, use, sharing and retention of personal data from the European Economic Area and Switzerland, as described in the EU-U.S. Privacy Shield certifications and Swiss-U.S. Privacy Shield certifications of AWS.  Click here for more information concerning such certifications of AWS.  

 
 

Children’s Privacy 

Our Site is not directed to individuals under the age of 16, and we request that individuals under 16 not provide personal data to ITCC.  If we learn that we have collected personal data from a child under 16, we will take steps to delete the information as soon as possible.  If you are a contact of one of our customers, you should review their privacy policy to determine their privacy practices with respect to children’s data.   

 

Retention of Personal Data 

ITCCwill retain your personal data for only as long as needed for the purposes for which the personal data is processed and to meet ITCC’s legal obligations.  See section below under “Your Rights” for additional information pertaining to the right of erasure, as well as other data subject rights. 

 

 

Information Security 

We implement appropriate technical and organizational measures designed to assist in maintaining the security and confidentiality of personal data; safeguarding against anticipated threats to the confidentiality, integrity and availability of personal data; and protecting your personal data against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access.  Such technical and organizational measures include all applicable security requirements in accordance with the Payment Card Industry Data Security Standard. 

 

However, whenever personal data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party.  No system or online transmission of data is completely secure. In addition to the technical and organizational measures that ITCC has in place to protect your personal data, you should use appropriate security measures to protect your personal data.  If you believe that your ITCC account or any information you provided to us is no longer secure, notify us immediately at wa.privacy@personifycorp.com. 

 

Your Rights 

Right to Object 

If you reside in the European Union, you have a right to object to the processing of your personal data for direct marketing purposes, including profiling related to direct marketing. “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a data subject, such as when we provide you with a specific type of direct marketing information based on information you provided us when you signed up for a ITCC account (e.g., your location or organization type).  If you exercise your right to object to processing for direct marketing purposes, including profiling related to direct marketing, ITCC will no longer process your personal data for such purposes. 

 

Additionally, if you reside in the European Union, you have a right to object when we process your personal data based on the legitimate interests of ITCC or a third party. If you exercise your right to object where our processing or sharing of your personal data is based on legitimate interests that may result in the cancellation of your account. ITCC will no longer process or share the personal data covered by your objection unless ITCC has compelling legitimate grounds for the processing or sharing that override your objection or that relate to the establishment, exercise or defense of legal claims.  

 

 

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Data Controller  

If your personal data was collected by and on behalf of ITCC (e.g., personal data of a customer collected through our website), then such personal data is controlled by WildApricot, Inc., which is located at 144 Front Street West, Suite 725, Toronto, Ontario, MSJ 2L7, Canada and which you can contact by email at wa.privacy@personifycorp.com. However, if your personal data was collected by or on behalf of a WildApricot customer, then such personal data is controlled by our customer, with WildApricot acting as a data processor. 

Privacy Policy Updates 

We may update this Privacy Policy from time to time as we add new services, as we improve our current services, and as technologies and laws change.  You can determine the effective date of this Privacy Policy by referring to the “Effective Date” legend at the top of this Privacy Policy. 

 

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent.  Such notice will be provided on the WildApricot website.