Privacy Policy

Last modified: October 2020

 

 

This Privacy Policy describes the way Docler Services S.à r.l., (hereinafter, “we”, “our” or “us”) collects, uses, shares and stores the personal information of individuals visiting our website (hereinafter “Visitor”) and individuals who register as members (hereinafter “Members”) of www.doclertechtalks.com (hereinafter the “Website”).

We operate our site and our services in compliance with applicable data protection laws, including the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA"). For more information, please see Section 6 "YOUR RIGHTS UNDER GDPR". If you are a California resident, please also see section 7 "INFORMATION FOR CALIFORNIA RESIDENTS."

Your privacy is important to us. We provide you with this Privacy Policy, so that you can make informed choices about the use of your data.

As used in this Privacy Policy, the term "personal data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. For example, under CCPA Personal Data includes identifiers such as your real name, alias, or postal address; Internet or other electronic network activity information, including, but not limited to, browsing history, and search history. CCPA § 1798.140(o)(1).

Please read this Privacy Policy carefully. This Privacy Policy forms a part of and is incorporated into the Docler Tech Talks Terms and Conditions. By using the Website, you agree that the Terms and Conditions, including this Privacy Policy, forms a binding legal contract with you.

You can contact us if you have any question about our privacy practices. We will be happy to provide you any assistance you may need.

 

1. WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The following company decides how and why your personal data is processed, and for GDPR purposes is the “Data Controller”:

Docler Services S.à r.l., a private limited liability company incorporated in Luxembourg, with registered address at 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.

2. WHAT PERSONAL DATA DO WE PROCESS?

The data we collect and process varies depending on whether you are a Visitor or if you submit a request to our website to participate to one of our talks (Participant).

 

Personal data you provide when you submit a request

If you choose to submit a participation request on our Website, we will ask you to provide the following information:

  • First name

  • Last name

  • Email address

 

 

  • Information collected by cookies and other technologies

Like many websites and applications, we use cookies.

To learn more about how we use cookies and your choices, please check out our Cookie Policy

 

3.WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect for the following purposes:

Event submission

We process this information to perform the contract that we have with you. We use the personal data you provided us when submitting to an event on our website. The submission allows you to participate to the event you submitted to.

We process this information given our legitimate interest in developing and improving our Website and our users’ experience. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

Ensure a safe and Trusting Environment

To protect you and our business, we use your personal data to detect and prevent fraud/illegal activities, and for security & risk assessment.

We have a legitimate interest in keeping you and our business safe.

 

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data. For example, we must retain your information to maintain legally required accounting records.

We may also use your information to respond to requests of competent authorities or given our legitimate interest to establish, exercise or defend legal claims. If necessary, we would use your data to investigate issues.

 

4. WITH WHOM DO WE SHARE YOUR DATA?

We share a portion of your personal data with the following parties:

 

Entities of our Companies’ Group

We share your personal data with the following companies of our group based in Luxembourg and Hungary, as they are helping us to deliver the services to you:

  • Docler Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg

 

Service providers

We use carefully selected and trusted third parties, who act as service providers to our site. We ensure that they are bound by contractual obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

 

Law enforcement agencies or governmental authorities

To the extent permitted by applicable laws, we may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary for the following:

  • to comply with our legal obligations

  • to respond to information requests for fraud investigations and other alleged illegal activities

  • to enforce and administer our Terms and Conditions

  • to protect our rights or defend ourselves against any claims

 

Business transfers

Your information may be transferred to another entity of our group (i.e. reorganization, restructuring, etc.) or third party (i.e. sale, merger and/or acquisition, etc.) if part (more than 50%) or whole of the business (or related assets) is either directly or indirectly transferred or falling under the control of the new owner.

This would be the case providing the new owner operates in the same or similar line of business as ours and commits to comply with this Privacy Policy.

 

5. HOW DO WE PROTECT AND HOW LONG WE RETAIN YOUR PERSONAL DATA?

We implement various security measures, technical and organizational, to grant protection to your personal data against unauthorized access, modification, disclosure or deletion.

We implement data loss prevention systems against leakage, theft and data breach. We periodically test our IT systems and do penetration tests. Our Website incorporates reasonable security technologies available to ensure safety of its users and the safekeeping of their related information.

We will retain personal data for as long as we consider it necessary to:

 

Provide you the service

For example, we may keep your information in order to calculate the Participants submitted to an event.

 

Legal Obligation Compliance

For example, we may keep some of your information for legal reporting and auditing obligations.

 

Legitimate Interests and Business Conduct

Including:

  • Establishing, exercising or defending legal claims

  • Fraud/illegal activity detection and prevention

  • Enhancing Safety

 

Security

As we have said, the protection of your information and our Website from accidental or malicious loss and destruction is one of our top priorities.

If you have a question about any specific retention periods of certain personal data, please contact us via the contact details provided in clause 8: "How to contact us?".

 

6. YOUR RIGHTS UNDER GDPR

 

Information on the transfer of your personal data outside of the European Economic Area?

As we are a Luxembourg based company, we comply with the EU Data Protection Regulation, “GDPR.” Regardless of whether you are located in Europe or elsewhere, our own location in Europe requires us to comply with GDPR. You can read the entire Regulation here.

During the course of the operation and exploitation of the site and the provision of the services, your personal data may be transferred outside of the European Economic Area (“EEA”) to third parties data processors located in the United States and other countries outside of where you live, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

What are Your Rights Regarding Your Personal Data?

We have done our best below to explain what your rights are under GDPR and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, you can contact us and we will provide you with all the assistance you need when exercising your rights. You may also contact us, at any time, before exercising any of your rights, and we will reply to your request as quickly as possible.

We will provide you with information on actions taken within one month of the day of receipt of your request. Only in exceptional circumstances, when we face complex and a high number of requests, we may extend this period of response up to two further months.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Please also understand that, because your privacy is so important for us, we may ask you to provide additional information before executing your request.

  • Data access and data portability

You have the right to access the personal data that we hold about you by requesting a copy of your personal data, free of charge, sending us an email to privacy@doclerholding.com.

If we consider that your request is manifestly unfounded or excessive (e.g., due to multiple requests in a short period), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you with the information.

In certain cases, you are also entitled to request copies of personal data that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). To exercise this right, you can send an email to privacy@doclerholding.com

Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can send us an email to privacy@doclerholding.com

 

Data Erasure

If you no longer want us to use your information, you can request that we erase your personal data.

If you face any difficulties on your request, please contact us at any time.

Please note that even if you request the erasure of your personal information, we will retain some of it for as long as we consider it necessary for compliance with our legal obligations or other legitimate interests as explained above in section 5 “How do We Protect And How Long Do We Retain Your Personal Data?”.

  • Right to object

We process your data for a variety of reasons as explained in section 3 “Why do We Process Your Personal Data?”.

Applicable law may entitle you to require us not to process your personal data for some specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for those purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

  • Right to restriction of processing

You have the right to request that we stop processing your personal data, while we resolve any issues.

This is only possible in the following four cases:

  • Accuracy: If you contest the accuracy of your personal data, processing would be stopped while we verify your claim.

  • Legitimate Interest: If you object to a processing activity based on legitimate interest, you can require the processing operation to be put on hold while we verify your grounds for objecting.

  • Unlawful Processing: You can request the restriction of data processing if you consider your data is being processed unlawfully, but do not wish your data to be immediately erased.

  • Data Storage: We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may continue to process your data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

  • Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (e.g. your local authority or the CNPD).

7. INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, you have the following special rights under the California Consumer Privacy Act (“CCPA”) in addition to any other rights outlined in this Privacy Policy.

Please note that we do not “sell” your personal data, as that term is defined in CCPA.

 

Your Right to “Know” and to Request Deletion

You have the right to know the categories and specific pieces of personal data we have collected about you. You have the right to know the categories of sources from which the personal data has been collected, the business or commercial purpose for collecting or selling personal data, and the categories of third parties with whom we share personal data.

You also have the right to request deletion of personal data we’ve collected or maintain. Please note this right is subject to certain exceptions, including without limitation our retaining information as necessary to protect against malicious, deceptive, fraudulent, or illegal activity, to comply with our legal obligations, and for other internal purposes.

To exercise these rights, you can contact us as provided in Section 9 “How to Contact Us?”. Please note that any requested disclosures in connection with a request to know will only apply to the 12-month period preceding the request, and you are entitled to request disclosure twice in any 12-month period.

 

Personal Information Disclosed

You also have the right to know what categories of personal data we’ve disclosed for a business purpose, and the third parties to whom that information was disclosed.

 

Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please note, however, that the exercise of some of your rights (e.g., to delete your data) may render it impossible for us to continue to deliver services to you.

 

Your Right to Use an Authorized Agent

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section 9 “How to Contact Us?” below. In order to verify you have authorized an agent we may require a signed, written authorization from you.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will however treat any “do not sell” or similar signals as opt-out requests under CCPA.

8. CHANGES TO OUR PRIVACY POLICY

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we are handling your personal data or changes in the applicable laws.

If we make any important changes, we will let you know by placing a notice on the relevant site and/or contact you directly, using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force. Your continued use of our site from that day on will be subject to the new Privacy Policy.

 

9. HOW TO CONTACT US?

If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to privacy@doclerholding.com or via mail to the address indicated below, and we will get quickly back to you. We are always glad to talk about our privacy practices.

 

Docler Services S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

 

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at:  dpo@doclertechtalks.com or mail to the following address:

 

To the attention of the DPO

Docler Services S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg