Data Protection Policy
This disclosure is given to members, and prospective members, of The International Castor Oil Association (“ICOA”) in compliance with the General Data Protection Regulation (“GDPR”) adopted by the European Commission effective May 25, 2018.
The GDPR generally regulates the “processing” of “personal data” by “controllers” and “processors.” Although ICOA does not, in the generally-understood sense, “process” any “personal data,” it appears that ICOA must comply with the GDPR because our collection of EU members’ names and identifying personal information (such as address, phone number and email) is technically the “processing” of “personal data.” Accordingly, our legal counsel has reviewed the 99 articles of this regulation, and we provide this disclosure to inform EU residents of their rights under the GDPR. A complete copy of GDPR will be provided, upon request, to any member. The address of ICOA is P.O. Box 595, Mohegan Lake NY 10547 (USA). The best means of communicating with us is using email addressed to email@example.com.
ICOA collects members’ personal data
Notice is hereby given that ICOA collects the following “personal data” and maintains it as set forth below:
a. Name, address, company affiliation, phone number, email address. This personal data is not shared with third parties, and is only made available to other ICOA members either on the “members only” section of our web site, or in printed and digital matter created and disseminated among attendees at ICOA annual conferences. This personal data is defined hereafter as “Membership List Personal Data.”
b. We occasionally post on the ICOA web site, photographs of persons attending our annual conferences. These photographs are available for third parties to view, and might be considered “personal data” under GDPR. This personal data is referred to hereafter as “Website Photos.”
c. We occasionally post articles of interest on the ICOA web site, sometimes written by members. In such cases, the member providing the article or matter to be published is aware that their names and selected personal data may be incorporated and available to third parties. This personal data is referred to hereafter as “Website Personal Data.”
We do not collect “cookies” on our web site, nor do we profile members or process/manipulate personal data in any other way. You have the right to request to know the personal data that ICOA collects and maintains concerning you, to assure its correctness, or for any purpose.
Why we collect your personal data
We collect the Membership List Personal Data to maintain a list of our members, so that ICOA will know who are our members, and be able to communicate with members about ICOA business. If you believe that ICOA should not maintain your personal data on our membership list while you are an ICOA member, you may have the right under GDPR to object to our maintenance of such data. We believe that our collection of data is permissible “processing” of “personal data” under GDPR Article 6, Section 1 (b) and (f). We believe that the provision of personal data is a contractual requirement under our by laws, or a requirement necessary to enter into a contract under the by laws, which the data subject is obliged to provide in order to be a member if ICOA.
We collect Website Photos to promote the activities of ICOA. If you believe that ICOA should not maintain this personal data on our web site, you may have the right under GDPR to object to our maintenance of such data; any photo depicting you will be deleted promptly upon request. We believe that our collection of data is permissible “processing” of “personal data” under GDPR Article 6, Section 1 (b) and (f). We believe that the collection and use of Website Photos is for the purposes of the legitimate interests pursued by ICOA. Members are not required, by law or by contract, to provide Website Photos.
We collect Website Personal Data to promote the activities of ICOA and to advance the state of the castor industry. If you believe that ICOA should not maintain this personal data on our web site, you may have the right under GDPR to object to our maintenance of such data; any matter containing Website Personal data relating to you will be deleted promptly upon request. We believe that our collection of data is permissible “processing” of “personal data” under GDPR Article 6, Section 1 (b) and (f). We believe that the use of Website Personal Data is for the purposes of the legitimate interests pursued by ICOA. Members are not required, by law or by contract, to provide Website Personal Data.
With whom do we share your personal data
ICOA does not share Membership List Personal Data with any third party. ICOA believes that its data protection policies provide assurance that all personal data maintained by ICOA will not be breached by third parties. Website Photos and Website Personal Data are shared to the extent set forth above.
For how long do we maintain your personal data
We only maintain Membership List Personal data on our member lists while the person is a member of ICOA; such personal data of a member is deleted within six months after the member ceases to be a member. Provided, however, that certain persons who cease to be ICOA members may have the right to continue to enjoy certain rights under the ICOA Constitution and By Laws, including the right to attend Board meetings and ICOA conferences. Such individuals’ personal data will be maintained for so long as these individuals continue to enjoy such rights.
Website Photos and Website Personal data are maintained on the ICOA website for so long as ICOA considers the information to be of value to ICOA (or such sooner time as a member requests its deletion). There is no set time limit for the maintenance of such personal data.
Members’ right to request correction, deletion and portability of personal data
Members have, at all times, the right to request from ICOA access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability. Upon request, personal data will be deleted consistent with GDPR Article 17.
Right to file complaints
Members also have the right to lodge a complaint with a supervisory authority.
Members are encouraged to review the entire text of GDPR, the text of which is being posted on the ICOA web site. If you have questions or comments, or you perceive any defects or aspects by which our Personal Data Protection Policy fails to comply with GDPR of applicable laws of member states, please email us immediately. Note that member states of the EU may have enacted laws in addition to GDPR, which may alter the rights, and the rules and regulations set forth herein.
Adopted by the Board of Directors on June 17, 2021