From our team to you
Privacy statement direct marketing to prospects
1. Identification of the controller
Vlaams Instituut voor Biotechnologie, with registered office at Suzanne Tassierstraat 1, 9052 Ghent, with company number 0456.343.923 ("VIB", "us", "we"), is responsible for the collection and use (or - as the law calls it - "processing") of your personal data as explained in this Privacy Statement which contains specific provisions on direct marketing. If you have any questions about VIB's processing of your personal data, please contact us by sending an email to [email protected].
2. What data do we process and how did we collect the data?
VIB processes your name, first name, e-mail address and the research field in which you are active to send direct marketing to prospects. This personal data is collected online through publicly available sources such as websites with contact information of researchers involved in relevant research areas for the conferences we promote. Using a case-by-case analysis, we make an assessment regarding the reasonable expectations of data subjects to receive our commercial messages.
Furthermore, in direct marketing emails, VIB also uses certain pixels that collect information about the success of our campaigns. For example, they allow us to find out whether our emails are opened and whether certain links in the emails are clicked on. If we did not use this technique, we would not be able to find out whether recipients are interested in our message. The pixels thus allow us to improve our campaigns and make them more relevant to current and future prospects. In addition, this information is also used to stop sending messages to a prospect with whom no meaningful interaction has been established.
3. Legal basis
The legal basis on which we rely to send prospects direct marketing messages is our legitimate interest to contact prospects with offers relevant to them. The General Data Protection Regulation ("GDPR") provides in recital 47 that "the processing of personal data for the purposes of direct marketing may be considered as carried out for the purposes of a legitimate interest."
The Belgian Data Protection Authority ("GBA") has also stated in its guidelines on direct marketing that this legal basis can be used in the context of prospecting when the impact on the privacy of the data subject is limited and the electronic direct marketing message is within the reasonable expectations of the prospect contacted. This position is explicitly confirmed on the GBA website.
The impact on the privacy of data subjects is substantially reduced as we implement the following measures that are conducive to privacy:
i. In-depth segmentation of the target audience to ensure that the message meets the reasonable expectations of the data subject. VIB segments on specific research fields that are closely related to the topics discussed at our conferences. If we collect your contact information through PubMed, we will send you direct marketing messages only if the article in which you are listed as an author was published within the last two years prior to our communication. In doing so, we can guarantee that the individual is part of the target audience potentially interested in our offerings.
ii. Being transparent to data subjects about the processing of their personal data by adding a clear disclaimer to each email (see Appendix 1) and providing a link to the specific privacy statement (the one you are reading now).
iii. Provide an opt-out option in the form of an unsubscribe link in every direct marketing message.
iv. VIB will automatically stop sending direct marketing messages when the recipient does not interact with three consecutive emails. To be clear, eight months prior to the conference, VIB will start sending direct marketing messages to prospects. Over this time period, we will send a total of six emails. Specifically, VIB will no longer send direct marketing messages when someone has not opened any of our emails for four months. However, personal data will remain stored because we need to prevent that you would be invited to a similar conference again in the future. In principle, this corresponds to the "right to object" under the GDPR (or in the context of direct marketing: right to unsubscribe) whereby a particular processing activity ceases, only in this case you do not have to express the right yourself.
4. Data sharing with third parties and international transfers
In principle, we do not share your personal data with third parties outside of VIB. We disclose personal data to government agencies and law enforcement authorities only if required by law or to comply with court requests. We may also share personal data with third-party service providers (so-called "processors") that we hire to process personal data on our behalf. These companies perform technology maintenance services or work on our behalf to conduct business transactions, such as providing customer services and sending marketing communications about our products, services and offers. An example of such a processor that VIB uses is ActiveCampaign.
Should VIB use a processor located outside the European Economic Area for which an adequacy decision has not yet been adopted by the European Commission, measures will be implemented (such as, but not limited to, adding model contractual clauses to the processor agreement) to ensure the secure transfer of your personal data. Additional technical, organizational or contractual measures will be implemented if the model contractual clauses are not sufficient to increase the level of data protection to that required under the provisions of the GDPR. Our processor ActiveCampaign is based in the United States. The international transfer of personal data is in accordance with the provisions of the GDPR as ActiveCampaign is certified under the so called Data Privacy Framework, the adequacy decision between the EU and the US. Furthermore, we have also chosen to have your data stored in ActiveCampaign's European data center.
5. Your rights
In accordance with the provisions of the GDPR you have the following rights regarding your personal data:
Right to information
You have the right to be informed about how your personal data are processed (in particular what personal data are processed, for what purposes and on what legal basis). The Privacy Statement you are reading now aims to do exactly this.
Right to access
You have the right to access your personal data and request a copy of the personal data.
Right to rectification
You have the right to have incorrect personal data corrected, or incomplete personal data completed.
Right to deletion
You can request the erasure of personal data held about you. The request to erase your personal data cannot always be granted, for example due to contractual or legal obligations.
Right to object
You have the right to object to the processing of your personal data, e.g. if the processing is carried out on the grounds of legitimate interest or the public interest of VIB processing your data. If your personal data is used for direct marketing purposes, you have an absolute right to object to this processing activity.
You can always exercise this right by clicking the unsubscribe link in the footer of the direct marketing e-mail.
Right to restrict
You have the right to obtain restriction of processing in certain situations, for example if you dispute the accuracy of personal data, for a period of time that allows VIB to verify the accuracy.
Right to data portability
You have the right to receive personal data concerning you, processed by VIB, in a structured, commonly used and machine-readable format and/or to transfer such data to another controller.
Right to file a complaint
In case of problems, we encourage you to contact VIB to reach an amicable agreement. However, if you consider that an amicable settlement is not possible or desirable, you may exercise your right to file a complaint with the Belgian Data Protection Authority:
Gegevensbeschermingsautoriteit, Drukpersstraat 35, 1000 Brussels, Tel +32 (0)2 274 48 00, e-mail: [email protected].
If handling your request requires unreasonable measures (e.g. it is technically or organisationally virtually impossible or extremely costly), VIB may charge you a reasonable fee in light of the administrative costs involved in handling the request. We may also refuse to process requests that are excessive, in particular due to their repetitive nature.
You may exercise these rights by sending an email to our Data Protection Officer ("DPO") at the following email address [email protected]. We will handle your request in accordance with applicable privacy laws.
6. Security
We have implemented technical and organizational security measures to prevent the destruction, loss, forgery, alteration, unauthorized access or disclosure of your personal data to third parties and any other unauthorized processing of such data.
We have made every effort to ensure the confidentiality, integrity and availability of the information systems and services in which personal data are processed. All our employees and third parties engaged by us are obliged to respect the privacy and security of your data.
7. Contact details
If you have any questions regarding this privacy statement, please contact us at [email protected] so that we can assist you further.
Appendix 1: privacy disclaimer in direct marketing messages
You are receiving this email because VIB deems that, in light of your professional activities, you may be interested in this offer. We process the following personal data: your name, first name, email address and the research field in which you are active. Rest assured that your data will be kept safe and not used for any other purposes. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of this email. If you would like to read more about VIB's processing of your personal data, please consult our specific privacy statement here.
Copyright © 2023. All Rights Reserved.