US ALUMNI CLUB CIC

NOTICE OF EU PRIVACY POLICY

US Alumni Club CIC (the “USAC”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by USAC is controlled by USAC and USAC is the data controller of your personal information.

Where your details are provided to USAC as a consequence of your participation in a USAC or member alumni club or partner or sponsor sponsored event, then USAC, acting as a data controller, may itself (or through a third party) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (the foregoing collectively, “Your Personal Information”).

USAC’s data protection officer can be contacted at ashwintirodkar <at> gmail.com.

This policy (the “EU Privacy Policy”) explains the manner in which USAC collects, utilizes and maintains non-public personal information about members and subscribers (“Members”) based in the European Union (“EU”) or the European Economic Area (“EEA”), as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This EU Privacy Policy applies to your membership or potential membership in USAC.

Collection of Your Personal Information

USAC collects Your Personal Information from the following sources, as applicable:

  1. Subscription documents and other information provided by the Member in writing, in person, by telephone, electronically or by any other means (this information includes (i) name, address, educational institutions attended and years of attendance, academic and other qualifications, and social interests and (ii) in the case of individuals, birth date, nationality, and employment information, or in the case of entities, date and jurisdiction of formation, entity type, tax identification number, and business information);

  2. Publicly available data sources; and

  3. Other interactions with USAC (for example, discussions with our staff and volunteers).

Why We Use Your Personal Information

Your Personal Information may be processed by USAC (or any of affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:

  1. to facilitate your participation in events organised by the USAC or its member alumni clubs or partners and sponsors;

  2. to comply with their legal obligations;

  3. to disclose information to other third parties such as service providers of USAC (including, for example, attorneys, accountants, auditors, or other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on USAC or in order to pursue the legitimate interests of USAC;

  4. to monitor and record electronic communications and if applicable, calls, for any of the purposes specified herein; and/or

  5. to otherwise pursue the legitimate interests of USAC relating to your membership or your potential membership in the USAC, and/or where the processing of Your Personal Information would be in the public interest.

Countries Having Access to Your Personal Information

USAC’s servers, which store and keep Your Personal Information, are located in the EU and the United States.

USAC also has service providers whose personnel will have access to Your Personal Information and that are located in other countries which have an adequate level of protection of Your Personal Information.

The disclosure of Your Personal Information to the third parties set out above may involve the transfer of data to the United States and other jurisdictions outside the EEA. Such countries may not have the same data protection laws as your jurisdiction. USAC has evaluated and will continue to evaluate the contractual arrangements that it has with its third party service providers to determine if additional contractual protections are needed.

Collecting Member Information Legally

USAC is able to legally collect and use Your Personal Information either because:

  1. You have consented to us doing so; and/ or

  2. Collecting and using Your Personal Information is necessary for USAC to fulfil our legitimate business interests, which may include (i) to fulfil contractual obligations to member alumni organisations or partners and sponsors; or (ii) to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum, or otherwise protect their legal rights; and/ or

  3. It is necessary to comply with any applicable regulatory, judicial or other legal obligation.

Retention of Member Information

USAC will retain Your Personal Information for the purposes described in (1), (2), and (3) in the immediately preceding paragraph as long as required for the purposes described above.

Your Rights

You have the right to:

  1. be informed about Your Personal Information that USAC collects from you, uses, and retains, which this EU Privacy Policy seeks to do;
  2. obtain confirmation from USAC that Your Personal Information is being collected, used, and retained as described above and to access Your Personal Information held by USAC;
  3. have Your Personal Information corrected if it is inaccurate or incomplete at any time;
  4. erasure, or the right to be forgotten, which means you can request deletion or removal of any of Your Personal Information USAC holds about you at any time, subject to USAC’s rights to retain Your Personal Information for legitimate business purposes;
  5. block or suppress USAC collecting and using Your Personal Information, which means USAC can continue to store Your Personal Information but cannot further collect or use it in any way;
  6. obtain and reuse any of Your Personal Information that USAC holds about you for your own purposes across different services, which allows you to move, copy or transfer Your Personal Information easily from USAC to another place identified by you to USAC in a safe and secure way without hindrance to the usability of Your Personal Information;
  7. object to USAC collecting, using or retaining Your Personal Information where this is based on:
    • your legitimate interest or the performance of a task in the public interest;
    • direct marketing even if otherwise legally permitted; and
  8. withdraw your consent to the use of Your Personal Information at any time, as described below.

To make any requests as listed above, please contact USAC at ashwintirodkar <at> gmail.com and info <at> usalumni.club.

USAC will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.

Withdrawal of Your Consent

You can tell USAC to stop collecting, using and retaining Your Personal Information at any time by emailing USAC at ashwintirodkar <at> gmail.com and info <at> usalumni.club.

You should note that notwithstanding your withdrawal of consent, USAC may be legally required to retain some or all of Your Personal Information.

Protection of Member Information

USAC maintains appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:

  1. the pseudonymization and encryption of Your Personal Information where appropriate;

  2. ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;

  3. ensuring USAC can restore access to Your Personal Information in a timely manner if a physical or technical incident occurs; and

  4. regular testing, assessment and evaluation of the effectiveness of its technical and organizational measures to attempt to ensure Your Personal Information is secure.

USAC restricts access to the personal and account information of Members to those employees who need to know that information in the course of their job responsibilities. USAC will destroy, erase or make unreadable data, computer files and documents containing Your Personal Information that is non-public prior to disposal.

Further Information

USAC reserves the right to change this EU Privacy Policy at any time. The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive. This EU Privacy Policy complies with the GDPR regarding privacy. You may have additional rights under other foreign or domestic privacy laws in addition to those that are described above. If you have any questions about this EU Privacy Policy, please contact us at ashwintirodkar <at> gmail.com and info <at> usalumni.club.

Making a Complaint

If you would like to make a complaint about the way USAC has collected, used or retained Your Personal Information, please contact us at ashwintirodkar <at> gmail.com and info <at> usalumni.club.

You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by USAC or its service providers infringes the GDPR.

Former Members

This EU Privacy Policy also applies to former Members in the EU and the EEA.