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1.    Introduction

This International Whaling Commission Policy (‘Policy’) outlines the information that the International Whaling Commission (‘IWC’, ‘we’, ‘us’ or ‘our’) collects, how we use that information and the rights you have to access, correct or delete information we hold.

 

2.    Who we are (the “Controller”)

The International Whaling Commission is the global body charged with the conservation of whales and the management of whaling.

International Whaling Commission
135 Station Road
Cambridge
CB24 9NP

Tel: +44 (0)1223 233971
Web: http://iwc.int
Email: secretariat@iwc.int

 

3.    Scope

This Policy applies to the IWC’s collection, use and disclosure of the information of the following categories of individuals:

Website Visitors:

Individuals who visit our Websites and who may opt to provide their email address to receive communications from the IWC. For the purpose of this Policy, “Websites” shall refer collectively to iwc.int, iwcoffice.org, blubber.io, ocet.io and their sub domains, as well as any other website the IWC owns that link to this Policy.

Meeting Delegates/Attendees:

Individuals who provide their information to the IWC or IWC representatives when they attend or register to attend an IWC event, or other events at which the IWC participates.

Contacts:

Individuals who have contacted us, who have provided us with their contact info, or whose details we have been passed in order to contact.

Contracting Governments

Officials from contracting governments such as commissioners and alternate commissioners.

This policy does not apply to any sub-committees or other IWC Entities who are outside the control of the IWC Secretariat. These sub-committees and entities are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information in connection with the use of our Services.

The IWC’s Websites and Services are not intended for, nor designed to attract, individuals under the age of thirteen (13). The IWC does not knowingly collect personally identifiable information from any person under the age of thirteen (13).

 

4.    What we collect

Website Visitors:

  • Contact details - including name, email address, and other contact information
  • Profile information – any other information you choose to provide such as date of birth and a bio
  • Log data – including IP Address & hostname, location, internet service provider, operating system and browser information, URLs and search terms of referring pages, locale and language preferences
  • Cookies, tracking and analytical information – providing us with information on how you interact with our Websites
  • Data submitted – our websites may offer the ability to submit data such as page comments, forum discussions, scientific and other databases, and file uploads. If you chose to submit data, please be aware that any information may be made public and form part of our permanent archives.

Meeting Delegates/Attendees:

  • Contact details - including name, email address, affiliation, registration preferences, photo, passport and visa information, accommodation details, and other profile information you provide
  • Payment information – If you are required to make a payment, or receive a payment we will collect information including invoices, expenses claims, bank account and credit card details
  • Details of attendance - such as sessions attended
  • Photos and recordings – some sessions may be photographed or recorded

Contacts:

  • Contact details - including name, email address, postal address, telephone and fax numbers, affiliation and any other profile information that you provide

Contracting Governments

  • Contact details - including name, email address, postal address, telephone and fax numbers, affiliation and any other information that you provide
  • Payment information – if contribution payments are required, we will collect information including invoices, bank account and credit card details

 

5. Legal Basis

Our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We collect information where:

  1. we have your consent to do so;
  2. we need your personal information for the performance of a contract or prospective contract you are party to (e.g. as a contracting government commissioner, or to provide you with meeting services);
  3. we have a legal obligation to collect your personal information;
  4. we may need the information to protect your vital interests or those of another person;
  5. we need the information for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  6. we have a legitimate interest. We have a legitimate interest in operating our Services to meet the needs of the Commission, and communicating with you as necessary to provide these Services (e.g. when responding to your queries, improving our services or for the purposes of detecting or preventing illegal activities);

Some data may form part of our permanent archives or be used for scientific, historical research or statistical purposes.

 

6.    Why we need it

For all categories of data that the IWC collects, we may use this information (including personal information) to:

  • provide, operate, maintain, improve and promote our Websites and Services;
  • enable you to access and use our Websites and Services;
  • contact you in relation to our Services and other duties;
  • process contracts and transactions;
  • process and publish submitted files and data;
  • create and publish distribution lists;
  • create and publish reports;
  • develop new services, features and functionality;
  • verify your age and identity;
  • send transactional messages;
  • provide customer service and support;
  • send technical notices, updates, security alerts, and support and administrative messages;
  • monitor and analyse usage, activities and behaviour on our Websites and Services;
  • comply with legal obligations as well as investigate and prevent fraudulent transactions, unauthorized access and other illegal activities;
  • review and process recruitment applications;
  • process grants, expenses and other payments;
  • perform research and other statistical analysis;
  • process for any other purpose for which we have your consent;

For contracting governments, we will additionally use your information to:

  • publish your contact information publicly on our website;

We may combine any information we collect from you with personal information we obtain from third parties. For example, approved participant list provided by a head of delegation or national collator.

 

7.    What we do with it

Your data may be passed to third parties and service providers who act on our behalf (‘Data Processors’) including those outside of Europe. They will only process personal information pursuant to our instructions and in compliance with this Privacy policy and other applicable requirements. We will ensure an appropriate Data Processor Agreement is in place and that they offer the same level of protection and safeguards to personal information as that required under UK and European law.

In addition to sharing data with Data Processors as described above, we may also share your information with others in the following circumstances:

  • with other IWC Entities (defined for the purposes of this Policy as the Commission, its Sub-Committees and their members)
  • with contracting governments
  • with meeting partners, such as, host country, hotels, travel agents and providers and security staff
  • when we are required to disclose personal information to respond to court orders and warrants, or legal process, or to establish or exercise our legal rights or defend against legal claims
  • where we believe in good-faith that sharing data is necessary to investigate, prevent, or act against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions or Service Agreements, or as otherwise required to comply with our legal obligations
  • publicly, as required by a specific Service or provision
  • as you may otherwise consent

The IWC may aggregate data we collect, including data described above. For example, we may aggregate log data to compile web traffic reports and statistics or meeting attendee numbers. Non-personally identifiable, aggregated data may be shared with third parties.

The IWC is headquartered in the UK. We primarily store your information in the European Economic Area (‘EEA’), Switzerland, the United States (‘US’) and Canada, however, due to the international nature of the IWC and its staff, we may transfer or access your information globally, including to international third parties and service providers.

If you are accessing or using our Websites or Services or otherwise providing us with information, you are agreeing to the transfer of your personal information outside of the EEA and Switzerland.

 

8.    How long we keep it

We retain personal information collected from you where we have an ongoing legitimate business need to do so, an ongoing or prospective contract or your consent.

When we have no ongoing need to process your personal information, we will either delete or anonymize it. If this is not possible (e.g. if your personal information is stored in a backup archive), we will securely store your personal information and isolate it from any further processing until deletion is possible.

Any data that forms part of our archives or is used for historical or scientific research or statistical purposes will be kept indefinitely.

 

9.    Your Rights

You can request to view, correct and export the personal information we hold on you. In some circumstances, you can also request your data be deleted.

You may email us at dataprotection@iwc.int with any such Subject Access Request (‘SAR’), and we will respond within thirty (30) days. Some information can be accessed, corrected or exported via your online account.

We will need to verify a SAR relates to the requesting person before we can assist. Where a SAR implicates the personal data of another individual, we must take in to account their rights and freedoms when processing the request. We will only comply with SARs to the extent required by applicable law.

If we rely on your consent to process data, you have the right to withdraw or decline your consent at any time. If we rely on legitimate interest, you have the right to object to the processing. You can do so by contacting dataprotection@iwc.int.

You have the right to opt-out of marketing communications we send you at any time. You can do so by clicking the ‘unsubscribe’ link at the bottom of each email.

If you wish to submit a complaint on how we have handled your personal data, you can contact us by email at dataprotection@iwc.int and we will investigate the matter.

If you are not satisfied with our response or believe we are processing your personal data illegally, you can complain to the Information Commissioners Office (‘ICO’).

 

10.    Safeguards

We will take all reasonable steps to protect your personal information from loss, misuse, unauthorised access, disclosure, alteration, and/or destruction.

We will ensure appropriate physical, technical and administrative safeguards are in place to secure your information.

 

11. Changes to this Policy

If we make changes to this Policy that we believe impact the privacy of your personal data, we will notify you of such changes, and post the updated Policy on this website.