This Privacy Notice is provided by ICMSA to its member contacts (i.e. contacts within or representatives of ICMSA member organisations), registered users of the ICMSA website (icmsa.org), visitors to the ICMSA website, and non-member enquirers (i.e. individuals who contact ICMSA – e.g. to request information).
ICMSA is committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Notice explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information.
Please read the following carefully to understand our views and practices regarding your personal information.
1. Who are we?
For the purposes of applicable data protection laws, the data controller is the International Capital Market Services Association (“ICMSA“) of The St Botolph Building, 138 Houndsditch, London, EC3A 7AR.
2. What information is covered by this Privacy Notice?
This Privacy Notice covers all personal information processed by ICMSA which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly.
3. What information do we collect from you?
We may collect information about you from the following sources:
Information we receive from you
We collect personal information that you provide to us:
- where you are a member, when you register on our members area of our website which is available only to registered member users (in this case, we collect your login credentials i.e. username and password);
- when you correspond with us as a member contact or registered user (e.g. to request technical assistance to access your member account on the members area of our website or use our online services; to enquire about any membership related matter). In particular, we collect your identification and contact information i.e. name, organisation, work phone number, work email address and your message to us; and
- when you correspond with us as a non-member to submit enquiries (e.g. in particular, we collect your identification and contact information i.e. name, organisation, work phone number, work email address and your message to us).
Information we collect about you
We receive personal information from your organisation when it applies for membership with us and it indicates you as its key membership contact. In particular, we collect your name, job title and work contact details (such as email address and phone number). We can also collect personal information from your organisation which is necessary in relation to other purposes which are part of our core membership services, such as organising events for our members.
We also automatically collect the following personal information by means of cookies and other technologies when you visit our website:
- technical information, including your IP address, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
- information about your visit to our website (e.g. date and time of the visit); and
- length of visits to certain pages of our website, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.
4. How do we use your personal information?
|We use your personal information for the following purposes:||Based on the following legal justifications:|
|Process membership requests, grant membership status and administer membership||Necessity for the legitimate interest of ICMSA to carry out its trade association mission and necessity for the legitimate interest of ICMSA members to join ICMSA and receive the benefit of membership status.|
|Maintain and administer membership records||Depending on the circumstances, necessity for the legitimate interest of ICMSA to provide its membership services or compliance with its legal obligations (e.g. to preserve records for submissions to regulators or public authorities).|
|Provide membership communications (including promotional communications) and services (including organising member events) to our members; and respond to member enquiries||Necessity for the legitimate interest of ICMSA to carry out its trade association mission and necessity for the legitimate interest of ICMSA members to receive membership services and participate in member events, consultations, and decisions etc. We will request an individual’s consent to receive our marketing communications where this is required under the applicable law.|
|Organise events for ICMSA members and enable member contacts to participate in such events||Necessity for the legitimate interest of ICMSA to provide its membership services (including members’ events), necessity for the legitimate interest of ICMSA members to receive membership services and participate in member events, and necessity for the legitimate interest of our hosting members or partners to host our events and ensure that they run smoothly and safely.|
|Enable authentication and access to our website reserved area for online registered users; Provide technical assistance to online registered users in case of technical issues (e.g. to access their reserved area)||Necessity for the legitimate interest of ICMSA to carry out its trade association mission and necessity for the legitimate interest of ICMSA members to benefit from online reserved access as part of the membership pack.|
|Respond to enquiries from non-members (e.g. via our online contact form)||Necessity for the legitimate interest of ICMSA to promote itself externally and necessity for the legitimate interest of the general public or potential members to receive information from ICMSA.|
5. With which third parties do we share your personal information?
Our service providers: We use other companies, agents or contractors to perform services on our behalf or to assist us with the provision of the ICMSA services and products to you. We may share personal information with the following categories of service provider:
- infrastructure and IT service providers (e.g. cloud service providers);
- marketing, advertising and communications agencies;
- external auditors and advisers.
In the course of providing such services, these service providers may have access to your personal information. However, we will only provide our service providers with personal information which is necessary for them to perform their services, and we require them not to use your information for any other purpose. We will endeavour to ensure that all our service providers keep your personal information secure.
Our hosting members and partners: In connection with member events, we may share certain personal data relating to our member contacts (such as name, contact details, job title and company) with the member companies (or other hosting partners, such as venue providers) hosting those events.
Third parties permitted by law: In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, or judicial or administrative authorities).
We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.
6. Do we transfer personal information outside the EEA?
Your personal information may be transferred to and processed in countries outside the European Economic Area (“EEA“) (i.e. United States) by our service providers. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA. You can ask for a copy of such measures using our contact details as indicated below at “How can you contact us?”.
7. What are your rights?
If the processing of your personal information by us is subject to EU data protection law, you have the following rights:
- Access. You have the right to request whether and how we use your personal information and a copy of the personal information we are processing about you.
- Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
- Deletion. You have the right to request that we delete personal information that we process about you, except we are not obliged to do so in some cases such as if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
- Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim. You also have the right to opt out from marketing messages from us that you receive from us at any time.
- Withdrawing consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge.
You can make a request to exercise any of these rights in relation to your personal information by sending the request by email to [email protected].
You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.
8. How do we protect your personal information?
We have implemented technical and organisational security measures to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to consultants, directors, officers and representatives of ICMSA and to authorised service providers who need to know such information for the purposes described in this Privacy Notice, as well as other administrative, technical and physical safeguards.
While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
9. How long do we keep your personal information?
We will only retain your personal information for as long as necessary for the purpose for which the information was collected and to the extent permitted by applicable laws. When we no longer need to use any of your personal information, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.
10. How can you contact us?
If there are any questions or concerns regarding this Privacy Notice, please contact us as follows:
- by email: [email protected]
- by mail: The St Botolph Building, 138 Houndsditch, London, EC3A 7AR
11. What if this Privacy Notice changes?
We reserve the right to change our Privacy Notice where required from time to time. If we decide to change our Privacy Notice we will notify our members of the changes and post an alert on the home page of our website.