1. Sources and Types of Information Collected
International Wineries for Climate Action (IWCA) is committed to protecting the privacy of the data we collect from you when visit or use the services we provide through our website, or when you otherwise contact or interact with us.
We recognize personal data as any information related to an identified or identifiable individual.
This policy covers information collected through this website, including ‘personal data’ from website visitors, individuals who subscribe to our newsletter, members and applicants, and other collaborators or partner organizations. These categories of data subjects include individuals who reside outside the United States in the European Economic Area (EEA).
Sources and types of information we collect:
Third-party technologies: Google Analytics; Mailchimp; Zoho
Newsletter Subscribers: People who are interested in our work can sign up to receive our newsletter directly on our website. You may opt out of receiving this newsletter at any time.
Recruitment and membership: We are a membership-driven organization. As part of our outreach and recruitment processes, which include our project management, meeting, and logistic services, we may require your name, contact details, and some business information.
Vendors, Collaborators, and Contractors: to provide our services, we also contract with outside companies. To fulfill our contractual due diligence, we will collect information on these companies, including name, tax and bank account information, and contact information for key personnel.
2. Use of Information: Purposes and Legal Basis
The purposes for which IWCA collects and uses your personal data may vary depending on the type of relationship you have with us: whether you are a member or applicant members, prospective applicant member, a newsletter subscriber, or vendors, collaborators, and contractors.
We collect and use Personal Data from you according to the following purposes and legal basis:
We have a legitimate interest in conducting the following activities:
Newsletter subscribers: We use personal information to for the delivery of our newsletter. We also use technology to track how many emails that we sent were opened or viewed to better target our content and ensure it is of interest. We have a legitimate interest in promoting our activities and projects to interested individuals.
Downloads of the GHG Calculator: Anyone who would like to download our GHG Calculator will be required to share their name, organizational affiliation, and email address before accessing the Calculator. This is to allow us to record how many users have accessed the Calculator and to be able to contact these individuals with updates to the Calculator.
Information collected automatically: this information is used to support the operation of our website and to analyze the traffic patterns on our site. See our cookies notice for more information.
We may need information necessary for entering into or performance of a contract:
Members and applicant members: We use your data to share information with you about IWCA, plan events and meetings, and for all purposes related to your fulfillment of IWCA requirements (including submitting audited GHG inventories).
Prospective applicant members: We use your data to share information with you about IWCA to promote IWCA and provide information about how to apply for membership.
Vendors, Collaborators, and Contractors: We use personal data in order to provide our services, and contract with outside companies.
3. Disclosures to Third Parties
At times, IWCA engages third party contractors, service providers, and other vendors to help us accomplish the objectives of our organization. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.
We engage with our contractors, and other third parties for the following services: such as email communications and marketing software and social media communications. If the engagement involves the transmission of personal data, we require the service provider to treat that data consistent with this Policy. A contract to protect the personal data should be executed before any data is disclosed.
We may also disclose information in special cases when it is necessary.
4. International Transfers of Personal Data
If you are located outside the United States and you interact with IWCA’s website or provide us personal data, then your personal data may be transferred to the United States.
We transfer your personal data to the United States whenever you interact with us. The US has not sought, nor obtained adequacy status from the European Union. The level of protection of your personal data is not deemed equivalent to the one in the EEA, unless the receiving organization is self-certified under the EU-US Privacy Shield. As a not-for-profit organization, we are not able eligible to adhere to the EU-US Privacy Shield Principles.
For any project with European clients, we sign standard contractual clauses. When this is not possible, we transfer your personal data based on the derogations in Article 49 GDPR, particularly:
Explicit consent, for newsletter subscribers and certain processing in relation to organizing events or facilitating access to information – such as storing photos or documents;
necessity to enter and for the performance of a contract for with our project participants; and for working with third party contractors or vendors.
As a safeguard, we directly apply the GDPR provisions to your personal data. We do not engage in any onward transfers regarding your data, beyond the access that our processors have to your data, as a principle. We also carefully select our processors and require that they provide equivalent safeguard mechanisms.
5. Retention Periods
IWCA retains personal data in our records only for the length of time required to fulfill the purpose for which the data was collected.
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 processed. The retention period depends on the context in which we process data.
6. Your European Privacy Rights
If you reside or otherwise find yourself in the European Economic Area (EEA), IWCA is committed to processing your personal data lawfully and to facilitate the exercise of your data protection rights granted by European data protection law.
You can contact us at any time to discuss your privacy concerns or to exercise these rights. Email us at firstname.lastname@example.org.
Privacy rights under the European regulation:
Transparency and the right to information. We provide notice to our members, website users and other third parties who interact with us on how we use personal data in our day-to-day activities at the time of collecting personal data, or as soon thereafter as possible. We also publish this privacy notice for greater transparency.
Right to access, rectification, restriction of processing, erasure, and data portability. We provide you with access to your own personal data. In addition, we will rectify your personal data when it is incorrect or inaccurate, and we will ensure the right to erasure, portability and to restriction of processing when these rights are not incompatible with other legal obligations.
Right to object and withdraw consent at any time: For all marketing materials, you can opt-out any time, free of charge. All marketing e-mails provide a link to manage your e-mail preferences in the footer of the communication.
The right to object for other processing activities will be balanced to ensure that it is not incompatible with local regulations or our legitimate interests.
To exercise your rights:
You should send a communication in writing to email@example.com and provide the following information in order to verify your identity: Your first and last name, phone number, and email address. We will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.
If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority of your habitual residence, place of work, or place of the alleged infringement.
7. Data Security
IWCA is committed to the security, confidentiality and integrity principles. We take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access and use and we periodically review our security measures.
This site contains links to other sites. While IWCA strives to link only to sites that share our high standards and respect for privacy, we are not responsible for the privacy practices employed by other sites.
8. Changes to this Policy