The HURACT takes your privacy seriously, and we are committed to safeguarding and protecting your personal data. The Trust is a “Controller” for data protection law and the General Data Protection Regulations (GDPR) 2018 for what concern the EU members. This means that we are responsible for deciding how we hold and use personal data about you. We aim to be clear about how we use your personal data, and this privacy notice explains how we look after your personal data, what personal data we process and why. This notice is compliant with the Federal Law on Data Protection.
It is important that you read this privacy notice together with any other privacy notice we may provide when collecting or processing personal data. Hence, you are fully aware of how and why we are using your personal data.

What personal data do we collect and process?

We will collect, use and store personal data when you:

• Purchase training, by phone, via our website or at our offices.
• Sign up to attend one of our training, events or workshops.
• Sign up to our mailing list via our website.
• Sign up to our mailing in other contexts, such as events, workshops or training classes.
• Provide feedback about our services.
• Ask information regarding our products and service.
• Communicate with us.

The personal data we hold may include your:

• Name.
• Postal Address.
• Telephone Numbers.
• Email address.
• The organization you work for or to which you belong.
• Your role or occupation.
• Transaction history (for example, if you have attended at training, events, etc. or the information you have requested).
• Billing information.
• Preferences as to how we communicate with you about our activities, training or events.
• Information that is available publicly.

Special Categories of Personal Information

We may also collect and store sensitive information relating to disability if you require specific access arrangements for accessing our services. This sensitive information will be held securely and only used for this limited purpose.

Implications of not providing personal data

We only ask you to provide personal data when we have a good reason to do so, and there may, therefore, be implications if you do not provide particular information to us. If you choose not to provide us with the personal data requested, we will tell you about the particular implications of any such decision at the relevant time.

How do we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter or have entered into with you.
• When it is in our legitimate interests and your interests, and when fundamental rights do not override those interests. We consider our legitimate interest to be the management of HURACT activities and provision of the best service and experience possible.
• When we have your consent to contact you.
• When we need to comply with a legal or regulatory obligation.

We will use the data we have collected to:

• Contact you if there are any important changes to the services you have requested.
• Respond to feedback or information you have submitted, or respond to a request for information.
• Keep a record of your relationship with us, including purchase history.
• Ensure we know how you prefer to be contacted, and that the details we hold are accurate.

If you opt in to marketing communication, either by providing your contact details at events, seminars, training or enrolling to one of our services or subscribing to our newsletter we will:

• Tell you about changes to our services or information on new services, training, events, offers, and opportunities that we think you will find interesting.
• Analyse your personal information to create a profile of interests and preferences so that we can contact you with information most relevant to you.
• Keep a record of the emails we send you, and we may track whether these are received or opened so we can ensure we are sending relevant information. We may then track any subsequent actions online, such as buying services.
• Occasionally undertake customer research to help us understand how we can improve our products, services or communication to understand our clients better.

If you no longer wish to receive marketing information by email about our programme, offers, or customer research, or you think communication has been sent to you erroneously, you have the option to change any of your contact preferences at any time by logging into your account online, or by contacting HURACT using the contact details at the end of this notice.

An unsubscribe option will also be included in any email we issue.

If the personal data we hold for you is incorrect or incomplete, we would ask you to contact us as soon as possible to request that it be updated.

Using our website

• When you use our website, www.huract.ch, we use cookies for different purposes. Further details about how we use cookies are available in our Cookies Policy.

Data sharing and third parties

We engage the services of several third-party service providers, who act as Data Processors, to assist us with a number of our administrative and operative services, and we rely on their contractual obligation to us as the legal basis on which we share personal data with them. These third parties include our email distribution service and mailing house. We may also share personal data with professionals such as bankers, lawyers, auditors and insurers who provide us with professional services to help protect HURACT interests. These third-party service providers will only use your personal data to the extent necessary to allow them to perform the services they are contracted to provide for us. We require all third-party service providers to respect and safeguard the privacy of your personal data and treat it following the law. We do not allow them to use your personal data for their own purposes.
We will not share, rent or exchange any personal details with any other third parties without your agreement, unless we are required to fulfil our contract with you, or unless we are required to do so by law.

Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Besides, we limit access to your personal data to those employees and third parties who have a genuine business requirement to use it.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting or reporting requirements. If you are opt-in for marketing purpose, we will retain your data to notify you about our services as long as you decide to leave them there.
A copy of our Data Retention and Archiving Policy is available on request, using the contact details at the end of this privacy notice.

Changes to this notice
This privacy notice will be reviewed annually and updated as and when required. The most up to date privacy notice will always be available on our website. If we make any significant changes to this notice, we will clearly identify them in any updates we communicate.

Your duty to inform us of changes
The personal information we hold about you must be accurate and current. Please ensure that you keep us informed if your personal information changes.

Your rights under the data protection legislation

Under the data protection legislation, you have the following rights about the personal data we process. These are not absolute rights and can only be exercised in certain circumstances.

• The right to request a copy of the personal data we hold about you.
• The right to request that inaccuracies in your personal data be corrected or updated.
• The right to object to us processing your personal data where we are relying on a legitimate
  reason for doing so.
• The right to request a restriction on us processing your personal data or erasure of your
  personal data in specific circumstances.
• The right to withdraw the consent if we are relying on your consent to process your personal
  data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights), and we will aim to respond to all legitimate requests within one month. If the request is particularly complex or several requests have been made, it may take us longer to process your request, but this will be explained to you. We may also charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you have any questions about how your data is being processed, or the rights detailed above, please contact HURACT by email at info@huract.ch.