PRIVACY POLICY
FOR THE USE OF ICC VERIFICATION PLATFORM
1. About ICC
The International Chamber of Commerce (ICC) is the world business organization, the only representative body that speaks with authority on behalf of enterprises from all sectors in every part of the world. ICC was founded in 1919. Today it groups over 6 million members in more than 100 countries. It represents business interests at the highest levels of intergovernmental decision-making, whether at the World Trade Organization, the United Nations or the G20 ensuring the voice of business is heard. It is this capacity to bridge the public and private sectors that sets us apart as a unique organization, responding to the needs of any player involved in international commerce.
World Chambers Federation (WCF) is ICC’s working body uniting the global network of chambers of commerce and their respective business communities. As well strengthening links among chambers, WCF also helps individual chambers become more productive. As a non-political, non-governmental body, WCF is the backbone of the chamber community providing a platfom for chamber leaders to communicate and collaborate with each other on matters of mutual interest and facilitating beneficial partnerships.
The ICC International Secretariat is located at 33-43 avenue du Président Wilson, 75116 Paris, France. We can be reached by phone at +33 1 49 53 28 28 or by fax at +33 1 49 53 28 59.
2. ICC’s Privacy Statement
The purpose of this Privacy Policy is to inform accredited chambers and visitors of the procedures regarding the collection, use and disclosure of information on the ICC Verification platform (“Platform”), including any mobile versions or related mobile applications, collectively called ICC Sites, accessible on: https://certificates.iccwbo.org/ . ICC encourages you to carefully read this Privacy Policy.
The ICC Origin Verification platform is provided by ICC, acting on behalf of its working body, ICC WCF. Its aims to offer Customs Authorities and chambers the possibility to verify the authenticity of certificates of origin issued by chambers of commerce members of the International CO Accreditation Chain. By visiting the platform and providing information to ICC, you acknowledge that you have been informed and you consent to the Privacy Policy. If you do not wish your personal information to be used by ICC in the manner set out in this Privacy Policy, please do not provide us this information.
3. Nature of information collected
To sign up for the Platform, chambers choose to provide voluntarily some personal information. The categories of personal information that ICC may collect for the processing purposes described hereto are: family name, first name, organization, job title, professional address and email of the contact of the accredited Chamber.
ICC will ensure that Personal Data collected from chambers is strictly necessary for the purposes described in section 4 below.
4. Purposes of Data Processing
ICC, may use the personal information that you provide:
- to provide to Customs Authorities and chambers the point of contact to verify the authenticity of certificates of origin issued by chambers of commerce members of the International CO Accreditation Chain;
- to process and respond to questions and/or inquiries;
- to send newsletters, emails, or other communications relating to products and services that may be of interest;
- to recommend other ICC services and products;
ICC, or third parties on its behalf, may also use information provided in an aggregate and anonymous form for internal business and planning purposes, including to analyse trends and statistics.
5. Data retention
The personal data will be used primary for the purpose of verifying the Certificate of Origin and also of sending relevant communications. ICC will retain the personal data only for as long as it is necessary to complete the operations for which data has been collected or until you request to no longer receive communications from us, in accordance with applicable laws and regulations.
When you submit an enquiry to ICC, an email is sent directly to our secure email server. The details of the enquiry may be stored by ICC in our email archives.
6. Transfer of data
For the purposes mentioned in section 4, as a global organization, ICC may need to transfer and process the personal information in a country other than your country of residence and/or outside of the European Union, to/in countries which may have different data protection laws.
In this case, ICC will put in place appropriate and adequate operational, organizational, procedural, and technical measures in order to ensure the security and confidentiality of the personal data.
7. Security
Protecting chamber’s privacy and personal information is a priority for ICC. ICC has taken reasonable measures to protect the personal information from loss, misuse and alteration. However, please be aware that no data transmission over the Internet or storage technology can be guaranteed to be 100% secure. ICC can only take steps to help reduce the risks of unauthorised access to information/data. Each individual using the Internet user can also take steps to help protect his/her personal information and is encouraged to do so to further minimize the likelihood that a security incident may occur.
8. Your rights
- Right to request access, rectification, erasure, restriction processing, object to the processing, portability
The collected information is necessary for the chamber’s registration and, more generally, for the purposes described in section 4. It is subject to data processing at ICC. In application of the French law on data protection and the European Regulation on the protection of natural persons with regard to the processing of personal data and of the free movement of such data (General Data Protection Regulation “GDPR”) you will benefit from the right to access, rectification, erasure, restriction processing, object to the processing, portability. If you wish to exercise these rights and obtain all relevant information, please contact us at dataprotection@iccwbo.org
In which circumstances can you exercise your rights with ICC?
- Right of access
1. You have the right to obtain from the controller, confirmation as to whether or not your personal data is being processed, and, where that is the case, access to your personal data and the following information:
i. the purposes of the processing;
ii. the categories of personal data concerned;
iii. the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations;
iv. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
v. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
vi. the right to lodge a complaint with a supervisory authority;
vii. where the personal data is not collected from you, any available information as to it source;
viii. subject to the conditions provided by the GDPR, the existence of automated decision-making.
2. Where personal data is transferred to a third country or to an international organisation, you shall have the right to be informed of the appropriate safeguards relating to the transfer.
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies you may request, the controller may charge a reasonable fee based on administrative costs.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
- Right to rectification
You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure (‘right to be forgotten’)
1. You shall have the right to obtain from the controller the erasure of personal data without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
• the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• you withdraw your consent;
• you object to the processing on grounds relating to your particular situation including profiling and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing;
• the personal data has been unlawfully processed;
• the personal data has to be erased for compliance in accordance with European Union or French law.
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of the personal data.
3. The right to erasure shall not apply to the extent that processing is necessary for:
i. exercising the right of freedom of expression and information;
ii. compliance with a legal obligation to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
iii. archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing;
iv. the establishment, exercise or defence of legal claims.
- Right to restriction of processing
1. You shall have the right to obtain from the controller restriction of processing where one of the following applies:
i. you contested the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
ii. the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of its use instead;
iii. the controller no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;
iv. you have objected to processing on grounds relating to your particular situation including profiling pending the verification of whether the legitimate grounds of the controller override yours.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
3. When you have obtained restriction of processing pursuant to paragraph 1, you shall be informed by the controller before the restriction of processing is lifted.
- Notification obligation regarding rectification or erasure of personal data or restriction of processing
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform you about those recipients if you request it.
- Right to data portability
1. You shall have the right to receive personal data which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided, where:
i. the processing is based on consent; and
ii. the processing is carried out by automated means.
2. In exercising your right to data portability pursuant to paragraph 1, you shall have the right to have your personal data transmitted directly from one controller to another, where technically feasible.
3. The exercise of your right to data portability shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4. The right to data portability shall not adversely affect the rights and freedoms of others.
- Right to object
1. You shall have the right to object, on grounds relating to your particular situation, at any time to processing which is based on legitimate interests. The controller shall no longer process your personal data, unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
2. Where personal data is processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the time of the first communication with you, the right referred to in paragraphs 1 and 2 shall be explicitly brought to your attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
6. Where personal data is processed for scientific or historical research purposes or statistical purposes, you, on grounds relating to your particular situation, shall have the right to object to processing of your personal data, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- Right to object to automated individual decision-making, including profiling
1. You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
2. This right shall not apply if the decision:
i. is necessary for entering into, or performance of, a contract between you and the data controller;
ii. is authorised by European Union or French law and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
iii. is based on your explicit consent.
3. In the cases referred to in sub-paragraph (i) and (iii) above, the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, including the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
- Right to unsubscribe
If you no longer wish to receive communications, you may opt out by cancelling your subscription on the Platform by sending an email to wcf@iccwbo.org.
9. Cookies Policy
- General
Subject to your prior explicit consent where such consent is required by the applicable law in your jurisdiction, ICC Verification platform use “cookies” (i.e., small text files which are downloaded to a user’s device when visiting the ICC Sites) in order to improve navigation around the platform for the user and improve the quality of the platform.
- Which cookies are we using?
ICC uses cookies to save your logged in status and track that you have visited the site. This is useful for you and means that you do not have to login to access your preferences each time you visit the platform. This is also useful for us as it helps us gauge how many users have visited our platform.
- Audience measurement
The audience measurement services used to generate useful statistics attendance to improve the platform. We use Matomo.
Matomo is an open source web analytics platform. A web analytics platform is used by a website owner in order to measure, collect, analyse and report visitors data for purposes of understanding and optimizing their website. If you would like to see what Matomo looks like, you can access a demo version at: https://demo.matomo.cloud.
Purpose of the processing with Matomo: Matomo is used to analyse the behaviour of the website visitors to identify potential pitfalls; not found pages, search engine indexing issues, which contents are the most appreciated… Once the data is processed (number of visitors reaching a not found pages, viewing only one page…), Matomo is generating reports for website owners to take action, for example changing the layout of the pages, publishing some fresh content… etc.
Matomo is processing the following personal data:
Cookies
IP address
User ID
Custom Dimensions
Location of the user
Date and time
Title of the page being viewed
URL of the page being viewed
Screen resolution
Time in local timezone
Files that were clicked and downloaded
Link clicks to an outside domain
Pages generation time
Country, region, city
Main Language of the browser
User Agent of the browser
Session recording, mouse events (movements, content forms and clicks)
Matomo is not doing any profiling.
The legal basis to use Matomo: The processing of personal data with Matomo is based on legitimate interests. You can object to the tracking of your personal data by using the following opt-out feature settings.
Processing your personal data such as cookies is helping us identify what is working and what is not on our platform. For example, it helps us identify if the way we are communicating is engaging or not and how we can organize the structure of the platform better. Our team is benefiting from the processing of your personal data, and they are directly acting on the platform. By processing your personal data, you can profit from a platform which is getting better and better.
Without the data, we would not be able to provide you the service we are currently offering to you. Your data will be used only to improve the user experience on our platform and help you find the information you are looking for.
The personal data received through Matomo are sent to:
ICC
Matomo service provider: InnoCraft, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand“. (Matomo cloud privacy policy)
Details of transfers to third country and safeguards with Matomo: Matomo data is hosted in Germany and Ireland for back up.
If you wish us to not process any personal data with Matomo, you can opt-out from it at any time. There will be no consequences at all regarding the use of our platform.
The existence of automated decision-making, including profiling and information about how decisions are made, the significance and the consequences: Matomo is not doing any profiling.
- Managing Cookies
Cookies are managed by Tarte au citron https://tarteaucitron.io/en/
Parameters of web browsers by default are generally set up in such a manner to accept cookies but you can easily change those parameters by modifying your preferences. If you choose to deactivate cookies, some functionalities, pages or parts of the platform may not be accessible. ICC is not responsible in such cases.
For more information related to cookies parameters, you can consult the following websites:
CNIL – http://www.aboutcookies.org/en
Internet Explorer™ – http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
Safari™ – https://support.apple.com/en-gb/HT201265
Chrome™ – https://support.google.com/chrome/answer/95647?hl=en
Firefox™ – https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
10. Links to Other Sites
The platform may contain links to or from a number of third party websites (hereinafter referred to as “Third Party Sites”). ICC does not, in any way, control or operate the Third Party Sites. ICC is not responsible for the privacy practices, content, policies or actions of the Third Party Sites. This Privacy Policy is only applicable to general information processed by the ICC Sites, pursuant to information collected on ICC Sites. The use of any information you may provide to third parties on Third Party Sites, or which such parties may otherwise collect on other websites, is not governed by this Privacy Policy.
11. Social Networks
Social media plug-ins of social networks such as Facebook and Twitter or services with user-generated content features are integrated into the platform. Where the platform contain a plug-in to a social network site, these are clearly marked (e.g. with a Facebook button). If you choose to click on one of these buttons or links, your browser connects directly to the servers of the relevant social network. The other website’s privacy policy applies to any personal information you provide to that website. If you do not want the social network to collect the information about you, please review the privacy policy of the relevant social network and/or log out of the relevant social network before you visit the platform.
12. Updates to Privacy Policy
To the extent permitted by applicable law in your jurisdiction, ICC may, from time to time, revise or update this Privacy Policy. You agree to be bound by such modifications or updates. If we make material revisions to the way we collect or use your personal information such that we are using it for purposes that you have not consented to, we will notify you of the changes and, as the case may be, ask for your explicit consent.
Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Internet, accessible through the platform. By continuing to use the platform following such changes, you will be deemed to have agreed to such changes.
DATE 01/07/2024