Effective date: May 25, 2018
The Netherlands Helsinki Committee (“us”, “we”, or “our”) operates the website www.shrmonitor.org, www.nhc.nl website and www.defendersorviolators.info (the “Service”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
Name and Address of the Controller
The controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Name: Netherlands Helsinki Committee
2513 AM The Hague
Tel + 31 (0)70 – 392 6700
Fax + 31 (0)70 – 392 6550
Netherlands Helsinki Committee Websites
The Netherlands Helsinki Committee is responsible for the content and management of all websites related to our programmes. These websites are:
- Netherlands Helsinki Committee: nhc.nl
- Security and Human Rights Monitor: shrmonitor.org
- Defenders or Violators: www.defendersorviolators.info
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (‘Personal Data’.) Personally identifiable information may include, but is not limited to:
- E-mail address;
- Cookies and Usage Data; and
- Usage Data
We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We keep provided information as long as necessary for the purpose of which you provided it.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we may use:
- Session Cookies to operate our Service;
- Preference Cookies to remember your preferences and various settings; and
Security Cookies for security purposes.
Use of Data
The Netherlands Helsinki Committee uses the collected data for various purposes:
- To provide and maintain the Service;
- To notify you about changes to our Service;
- To allow you to participate in interactive features of our Service when you choose to do so;
- To provide customer care and support;
- To provide analysis or valuable information so that we can improve the Service;
- To monitor the usage of the Service; and
To detect, prevent and address technical issues.
Disclosure of Data
The Netherlands Helsinki Committee may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of The Netherlands Helsinki Committee
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
We will oppose the disclosure of your Personal Data within the possibilities provided to us by law.
We may employ third party companies and individuals to facilitate our Service (‘Service Providers’), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We use Google Analytics to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
The Netherlands Helsinki Committee uses the services of MailChimp to send newsletters and event invites. This service is provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
MailChimp is a service which organizes and analyses the distribution of newsletters. If you provide data (e.g. your e-mail address) to subscribe to our newsletter, it will be stored on MailChimp servers in the USA.
MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.
We may use MailChimp to analyse our newsletter campaigns. When you open an e-mail sent by MailChimp, a file included in the e-mail (called a web beacon) connects to MailChimp’s servers in the United States. This allows us to determine if a newsletter message has been opened and which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to your interests.
If you do not want your usage of the newsletter to be analysed by MailChimp, you will have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we send. You can also unsubscribe from the newsletter directly on the website.
Data processing is based on Art. 6 (1) (a) GDPR. You may revoke your consent at any time by unsubscribing to the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted from our servers and those of MailChimp. Data we have stored for other purposes (e.g. e-mail addresses for the members area) remains unaffected.
Completion of a data processing agreement
We have entered into a data processing agreement with MailChimp, in which we require MailChimp to protect the data of our customers and not to disclose said data to third parties. This agreement may be viewed at the following link: https://mailchimp.com/legal/forms/data-processing-agreement/sample-agreement
We use the services of ICT Teamwork for our regular business e-mail traffic. This party has taken appropriate technical and organizational measures to prevent abuse, loss and corruption of your and our data as much as possible. ICT Teamwork have no access to our mailbox and we treat all our e-mail traffic confidentially.
On the basis of the applicable Dutch and European legislation, you as a data subject have certain rights with regard to the personal data that are processed by or on behalf of us. We explain below which rights these are and how you can invoke these rights. You have the right to file a complaint with the Dutch Data Protection Authority at any time if you suspect that we are using your personal data in the wrong way.
Right of Inspection
You always have the right to inspect the data that we process or have processed that relate to your person or that can be traced back to you. You can submit a request to that effect to email@example.com. You will receive a response to your request within 30 days. If your request is granted, we will send you a copy of all data.
You always have the right to have the data that we process or have processed that relate to your person or that can be traced back to this. You can submit a request to that effect to firstname.lastname@example.org. You will receive a response to your request within 30 days. If your request is granted, we will send you a confirmation that the details have been changed on the e-mail address known to us.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.