Alliance Privacy Policy

The Global Alliance for Trade Facilitation (the “Alliance”) is a public-private platform jointly led by the International Chamber of Commerce, with its registered office at 33-43 avenue du Président Wilson, 75116 Paris, France (“ICC”); the World Economic Forum with its registered office at Route de la Capite 91-93, 1223 Cologny, Switzerland (the “Forum”); and the Center for International Private Enterprise with its registered office at 1211 Connecticut Avenue NW #700, Washington DC 20036, USA (“CIPE”) in cooperation with the Gesellschaft für internationale Zusammenarbeit (“GIZ”).

ICC, the Forum, CIPE and GIZ are autonomous legal entities.

Any reference to the Alliance in this Privacy Policy should be construed as a reference to ICC, the Forum, CIPE and GIZ. ICC, the Forum, CIPE and GIZ are considered to be Joint Controllers as defined in section 2. 

1. Purpose

The purpose of this Privacy Policy (the “Policy”) is to inform you as the data subject (hereinafter also referred to as “you” or “your”) of the collection, sharing and using of Personal Data (as defined below) which is obtained by the Alliance in connection to its projects, business meetings, conferences, events and any other Alliance activities.

2. Definitions

Applicable Data Protection Laws

Any laws regarding the Processing and free movement of Personal Data, including but not limited to the Swiss Federal Act on Data Protection of 19 June 1992 (Status as of 1 January 2014), the European General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and other applicable data protection laws, each as amended from time to time.

Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data (as defined in this section); where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.

Joint Controller

Where two or more controllers jointly determine the purposes and means of processing of Personal Data.

Personal Data

Any information relating to an identified or identifiable natural person “data subject”; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing

Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. What type of Personal Data does the Alliance collect?

3.1 Personal data that you provided voluntarily or received through referrals

  • Identification details (including your name, first name, date of birth, nationality, company or affiliation and title)
  • Contact details (including email address, postal address, telephone number)
  • Voice and image (including but not limited to your name, appearance, voice, biographical material as well as your performance and presentation)
  • IDs and passports
  • Banking details (bank account number, IBAN, etc.)
  • Dietary preferences

The Alliance will ensure that Personal Data collected from you is necessary for the purposes described in section 4 below.

3.2 Personal Data that the Alliance collects automatically

We may collect certain information automatically from your device when you register to an Alliance event organized by the Forum via TopLink platform (please see the Forum’s TopLink Privacy Policy) and the Alliance Website that is operated by ICC (please see the Alliance’s Website Privacy Policy). In some countries, including countries in Europe, this information may be considered Personal Data under Applicable Data Protection Laws.Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with TopLink or the Alliance Website (see above), including the pages accessed and links clicked.

3.3 Personal Data that the Alliance obtains indirectly from third parties

From time to time, the Alliance may receive personal information about you that it obtains from public sources (e.g. Internet).

4. Purposes of Data Processing

The Alliance, or third parties on its behalf, may use the Personal Data you provided to:

  • Enable you to travel to and participate in the events organized by the Alliance, to organize sessions during these events and to provide you with any other services in connection with your participation to these events
  • Manage logistics and security at the Alliance events
  • Send you information such as invitations to future activities, projects and/or events as well as newsletters or other informational materials in connection of Alliance activities
  • Deliver newsletters, emails, or other communications to you that you have signed up for or might have expressed interest in verbally or in writing
  • Conduct surveys and ensure appropriate follow-up related to Alliance activities such as monitoring and evaluation of projects
  • Report Alliance activities to donors as well as annual reports
  • Conduct internal data analytics and statistics
  • Process and respond to your questions and/or inquiries
  • Other legitimate interests for the purpose of planning and managing Alliance activities, projects and events
  • Facilitate communication and collaboration in connection with Alliance activities, projects and events
  • Engage potential partners and collaborators in Alliance projects and activities
  • Organize Alliance Steering Group activities

We will use the Personal Data we collect from you only for the purposes described in this Policy or for purposes that we explain to you at the time we collect your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you in accordance with Applicable Data Protection Laws.

5. Legal basis for processing Personal Data

The Alliance’s legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. The Alliance will normally collect Personal Data from you only where it:

  • Has obtained your consent (e.g. conducting surveys)
  • Needs your Personal Data to perform a contract with you (e.g. when you engage with the Alliance as a partner or consultant)
  • Has business legitimate interests not overridden by your data protection interests or fundamental rights and freedoms (e.g. organize and participate in Alliance events and other activities)
  • Is required to comply with local laws and regulations (e.g. disclose certain information to the local authorities where the Alliance organizes its events)

If the Alliance requests you to provide Personal Data to comply with a legal requirement or to perform a contract with you, you are obliged to provide us with this Personal Data. For example, Alliance may not be able to complete your registration to an event.

6. With whom does the Alliance share your Personal Data?

The Alliance may disclose your Personal Data to Alliance-associated staff members, including, but not limited to, its directors, officers, employees, consultants as well as Alliance partners, members (existing and potential), donors and service providers for the purposes outlined in section 4 of this Policy. The Alliance may also disclose Personal Data as may be required by Applicable Data Protection Laws or to protect the rights of the Alliance. The Alliance shares your Personal Data with local authorities to the extent deemed necessary by the Alliance for the purposes set forth in this Policy, in particular for security reasons or as required by mandatory local laws and regulations.

7. How long do we keep your Personal Data?

The Alliance will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Policy or until you request to no longer receive communications from the Alliance in accordance with Applicable Data Protection Laws. For example, we may retain personal data we obtain from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

8. International data transfers

For the purposes mentioned in section 4 of this Policy, as an international venture with a global network, the Alliance may need to transfer and process your Personal Data outside of Europe to/in countries which may have different data protection laws in place. Your Personal Data may be stored, accessed or otherwise processed by Alliance partners, consultants, participants, potential partners and collaborators outside of Europe such as United States or other countries where for example Alliance projects are being implemented. For more information about Alliance country projects please visit: https://www.tradefacilitation.org/country-projects/. In this case, the Alliance puts in place appropriate and adequate operational, organizational, procedural, and technical safeguards in order to ensure the security and confidentiality of your Personal Data, pursuant to all Applicable Data Protection Laws. These include implementing the European Commission’s Standard Contractual Clauses for transfer of Personal Data, which require all parties to protect personal information they process from Europe in accordance with the Applicable Data Protection Laws.

9. Your rights as data subjects

You have the following data protection rights:

  • You may request access to and obtain a copy of your Personal Data
  • You may also request that the Personal Data that is inaccurate or incomplete be rectified or completed
  • You may request that your Personal Data be erased under certain legal conditions (for example, where the Personal Data is no longer needed to achieve the purposes for which the information was initially collected)
  • In addition, you may object to the processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data under certain legal conditions
  • You have the right to opt-out of electronic marketing communications (e.g. Alliance newsletters) we send you at any time and free of charge. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or cancelling your subscription on the Alliance website (www.tradefacilitation.org)
  • Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent
  • You have the right to complain to a data protection authority about our collection and use of your Personal Data; for more information, please contact your local data protection authority; contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here

You may exercise any of the rights above at any time by contacting us as described under the “How to contact us” section below. We will respond to your request in accordance with Applicable Data Protection Laws.

10. Data Security

Protecting your Personal Data is a priority for the Alliance.

Specifically, the Alliance uses appropriate technical and organizational measures to protect the Personal Data that it collects and processes about you. These measures are designed to provide a level of security appropriate to the risk of processing your Personal Data. In particular, any Personal Data provided to the Alliance is handled with due care and security, and will not be used in ways other than as set forth in this Policy, or in any site/area-specific policies, or in ways that are not compliant with Applicable Data Protection Laws.

Finally, all Alliance employees who have access to and are associated with the processing of Personal Data are obliged to respect the confidentiality of all such Personal Data.

11. Updates to this Policy

We may update this Policy from time to time in response to changing legal, technical or business developments. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Policy changes if and where this is required by Applicable Data Protection Laws. You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy.

12. How to contact us
If you have any questions or concerns concerning this Policy or the way we process your Personal Data, or if you wish to exercise your data protection rights as described above, please contact us by filling in the form at https://wef.ch/MyData