Privacy Notice
This Privacy Notice covers the processing of personal data necessary for the activities of the Global Centre for Lactation Training(GCLT)™, referred to also here as the Centre.
This Privacy Notice applies to you if you are a person whose personal data is disclosed or submitted in connection with such activities.
Who We Are
We are the Global Centre for Lactation Training(GCLT)™ and our global Headquarters are located at 10301 Democracy Lane, Suite 400, Fairfax, VA 22030, USA (Phone: +1 703-560-7330; e-mail: info@gclt.org).
If you have any questions about how we process your personal data, please contact info@gclt.org. The Centre serves as the controller of the information you submit to us or we collect about you in connection with a training activity, course, or event, and the means through which it is processed.
Purpose
The purposes of the processing activities relate to the administration of the Centre’s training activities. We will use your contact information for sending occasional communications necessary related to your participation in such activities.
Legal Basis
If you are a participant in the Centre’s training, the legal basis we rely on for processing the personal data that you submit by filling out the registration form is the performance of a contract to which you are party and taking steps at your request prior to entering the contract. For other processing we use a different lawful ground.
When participating in GCLT’s training activities, the information collected about you will be for purposes of identity verification, administering the training activities, fraud prevention, security and integrity, and as otherwise required by law.
For processing of personal data related to your activity while logged in on our website, we rely on our legitimate interest to prevent unauthorised access, ensure security of our online presence and of your personal data, and ensure the accuracy of your personal data. For using your contact details to keep you informed about your training, we rely on our legitimate interest.
Categories of Personal Data
If you participate GCLT training activities, we process the personal data you submit with your registration form when contacting us to tell us about your particular situation, or in connection with your actual training activities. The required information that is strictly necessary for the administration of the training activities is marked with an asterisk in the registration form. Failure to provide this information will result in the impossibility to participate in the training activities or for us to provide such activities to you.
Recipients of Your Data
Generally, the Centre does not make your personal data available to any third party, other than our vendors, who process personal data on our behalf and follow a strict mandate (they act as processors), except as otherwise authorised by you.
Retention Period
According to our retention policy, we only keep personal data in our records as long as they are necessary for the purposes they have been collected and processed for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data; whether we can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting, or other retention requirements.
We adhere to our Data Retention Policy to determine how long we retain data, including personal data.
- We retain registration and training information, and all related materials and personal data, for 10 years.
- We retain correspondence with you related to administration of the training for 3 years.
- We delete special categories of data you share with us as soon as possible and we strictly restrict access to such data.
- We retain video recordings of any training activities for a period no longer than 90 days, unless necessary for resolving and documenting any such activities as permitted or required by law.
- We retain names, addresses, and training results permanently.
International Transfers
If you are located outside of the United States, the Centre may transfer personal data related to registrations and administration of the training activities to the United States. The United States has not sought nor obtained adequacy status for ensuring an equivalent level of protection of personal data, from the European Commission. There are risks associated to the transfers, but the Centre has put safeguards in place to protect your data after it is transferred.
To ensure the lawful transfers of personal data from the European Economic Area (EEA), the Centre relies on necessity for the performance of a contract as a derogation that allows international transfers to occur (Article 49 GDPR).
Your Rights
The Centre is committed to facilitate the exercise of your rights granted by data protection laws in a timely manner – the right to access your data, to ask for erasure, correction, restriction, portability of your data, or to object to the processing of your data.
In order to be able to reply to your request and if we are not certain of your identity, we may need to ask you for further identification data to be used only for the purposes of replying to your request. If you have any inquiries or requests, write to info@gclt.org or contact us through our postal address.
Access, Correction, and Other Requests
You have the right to obtain confirmation whether we process or not your personal data, as well as the right to obtain information about the personal data we process about you and to obtain a copy of this data.
You have the right to obtain erasure, correction (updating or completing your personal data), restriction, and portability of your personal data, under certain conditions.
Right to object
You also have the right to object at any time to receiving marketing materials from us by following the opt-out instructions in our commercial emails, as well as the right to object to the processing of your personal data based on your specific situation (only in those cases where we process the data on the basis of our legitimate interest, as detailed above). In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal obligations.
For all the processing operations that are based on your consent, as described above, you can withdraw consent at any time and we will stop those processing operations.
California Privacy Rights
California Civil Code Section §1798.83 allows California residents to ask organisations with whom they have an established business relationship to provide certain information about the organisations’ sharing of personal information with third parties for direct marketing purposes. GCLT does not share any California consumer personal information with third parties for marketing purposes without consent. California residents who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.
Concerns
If you have any concerns or questions about how your personal data is used, please contact our Privacy Officer at info@gclt.org.
If you are located in the European Economic Area and you believe we have not been able to deal with your concern, you have a right to raise this issue with your local data protection authority. You have the right to submit a complaint in the Member State of your residence or place of work of an alleged infringement of the General Data Protection Regulation (GDPR).