FMO is committed to protecting the privacy and security of your personal information. This Privacy Statement applies to our use of the personal data of the users of our Future-Minded Community Platform (‘you’ or ‘user’) on [www…..com] (‘the Platform’). The Platform enables stakeholders to engage with experts, exchange knowledge, network with other community members and join live or recorded webinars and online or hybrid events.
Financierings-Maatschappij voor Ontwikkelingslanden N.V. (‘FMO’) is the data controller of the personal data processed as described in this statement. You can find the FMO contact details on the last page of this statement.
In this privacy statement we explain why and how we use your personal data, your rights regarding this data, and the protections we have in place to safeguard it.
In this privacy statement you can read:
- Which personal data we collect and for which purposes
- How long FMO keeps your personal data
- With whom FMO shares your personal data
- How we protect your personal data
- What privacy rights you have and how to exercise these rights
- How we update this Privacy Statement and how to contact us
- Which personal data we collect and for which purposes
- To provide you with access to the Platform and its functionalities
1. Which personal data we collect and for which purposes
To provide you with access to the Platform and its functionalities
You can visit the Platform without creating an account, but there is only limited information visible. If you wish to actively participate in one or more communities, use the chat functionality on the platform, or enroll for events or join online webinars on the platform, you will need to create an account. To create an account, you will have to submit your email address and a user name. Via a welcoming email you need to activate your account, set a password and complete the preferred settings. Once you are logged in, you can edit your profile and add information, such as the company that you work for, location, sector, job title. You can also complete a ‘self-introduction’ and share your expertise and interests. You can choose if and to what extent your profile is visible to other participants. Through ‘my profile’ you can also indicate your preferences regarding receiving notifications related to specific content, your profile and contributions being viewed by other participants or only within specific communities that you may have joined. You can also delete your account should you no longer wish to use the Platform.
If you wish to register for an event organized on the Platform, you need to subscribe by clicking on the enroll button. We may ask you to also additional information to be able to organize the events, such as which seminars you would like to attend, dietary wishes and other information. We will only use the extra information, which may potentially include sensitive data, to organize the event and in compliance with applicable law.
When you enter the Platform and/or register for the Platform and any of its specific services, we need to process some personal data to perform the agreement with you that we are thus entering into with you. The processing of personal data by us for some of the specific purposes described above (for organizing events, for providing information about content etc.) is in our legitimate interests or in yours as a user to be able to operate a meaningful communication platform to the users (employees, contacts of our clients, investment partners or other third parties that have shown interest in joining). It is also in our interest to engage with our clients and partners and to build or maintain a relationship with the participants of our events. Where we provide you actively with information through notifications, we will have asked for your consent first as needed.
Information on your use of the Platform
In addition to the information you have provided yourself, we also collect some information when you are visiting the Platform, such as your status as a user (active versus non-active), your interaction on the Platform (first and last time logged-in, how many posts, posted content, group memberships, which events you have registered and attended).
Furthermore, FMO keeps track of high-level statistical information about the use of the platform, so not on an individual level, such as the number of visits, users and user log-ins per month, how many posts, new topics, events and groups in total per month. This information is collected via cookies by the platform.
To the extent the above is personal data, we process this data because it is in our legitimate interests to do so. Our interests are to increase traffic to our website and to improve the user experience on the website, without your right to e.g. privacy prevailing.
Complaints and contact form
The platform offers the possibility to contact us or fill in a complaints form. Information we can collect and use to process your request is: your name, e-mail address, region and country, details about your question or complaint and the outcome.
When you raise a complaint as a whistleblower, we have a strict procedure and will not reveal your identity unless you have provided us with consent.
We process the above personal data because it is in our legitimate interests to respond adequately and appropriately to any requests that our users may submit to us. We do this without their right to e.g. privacy prevailing. Where we provide for a complaints procedure for whistleblowers, this is to comply with legal obligations that we are subject to.
Improving the website
To make the Platform more user-friendly and to improve the user experience, we are placing cookies on your computer, mobile phone or other device so we can analyze how the Platform is used. Some cookies are only placed after you have given us consent for placing the cookies and using the information collected by these. Please read our Cookie Statement for more information about the cookies.
The content that has been uploaded on the Platform may include links to certain third-party websites, and/or videos. If you choose to visit a third party’s site, please be aware that the third party’s privacy statement, and not FMO’s, will govern your activities and any information you disclose while visiting their site. Please consult their privacy statements to know how they handle your personal data.
Requests from authorities
Where required, we process personal data to comply with lawful requests by public authorities, disclosure requests, or where otherwise required or authorised by applicable laws, court orders, government regulations, or regulatory authorities, such as the Dutch Central Bank (DNB). We may also do so where this would be needed for our legitimate interest to protect FMO and the financial sector, without your right to e.g. privacy prevailing.
2. How long FMO keeps your data
We will store your personal data for as long as is required or reasonably necessary for the purposes for which it was collected, as explained in this Privacy Statement, and in accordance with our Personal Data Retention schedule. Your personal data that we have collected and that we use for providing the Platform will be retained for as long as you are active on the Platform and for a period of 1 year thereafter. When you have not been logged on to the Platform for one year, we will send you an email to check if you would like to remain your access to the Platform. If you indicate that you no longer wish to use the Platform or if you do not respond, we will delete your account. We will also delete your account upon your request.
In some circumstances we may have to store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting, or necessary technical requirements. In that case we will follow the retention periods required by law and the Personal Data Retention Schedule.
3. With whom FMO shares your personal data
To operate the Platform and to be able to provide the functionalities set out in this Statement, we use third parties providing specific services in respect of the Platform who we may need to disclose personal data to. Third party providers that shall have access to the personal data on the Platform to deliver the relevant services include the provider of the SaaS platform that the Platform runs on, OpenSocial B.V., based in the Netherlands. The Platform is hosted by Platform.sh, using AWS servers in Ireland.
There are data processing agreements in place with our third parties and, as required, additional safeguards in place to protect your data. Sometimes we organize the event with partners. If that is the case, we will inform you of the relevant partner for the event that you wish to register for and that information may be shared with this partner. The online events on the Platform will be hosted within a Zoom environment, for EU based users hosted on Zoom’s premises in Germany.
FMO may disclose personal data when required by law or court order, or as requested by any government, regulator, or law enforcement authority/agency.
Where FMO, for the purposes outlined in this document, transfers personal data to any third party in countries outside of the European Economic Area (EEA) that have not been deemed to offer adequate protection, we will take appropriate steps to ensure that there is an adequate level of protection for personal data in place in accordance with applicable legal requirements. We shall sign additional contracts and implement (technical) measures as required. For example, we will conclude additional contracts or implement (technical) measures in case of transfers outside the EEA.)
4. How we protect your personal data
We will keep the personal data that we retain in connection with the Platform confidential in accordance with data protection laws and applicable FMO policies and procedures. We will take appropriate security measurements to ensure that the personal data is kept secure and safe from any loss or unauthorized disclosure or use. (Suspected) data breaches can be reported through DPO@fmo.nl.
5. What privacy rights you have and how to exercise these rights
You have several legal rights in relation to the personal data that we use from you. These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you
- the right to withdraw your consent to our processing of your personal data at any time
- in some circumstances, the right to receive some personal data in a structured, commonly-used and machine-readable format and/or to request that we transmit those data to a third party, where this is technically feasible
- the right to request that we correct your personal data if it is inaccurate or incomplete
- the right to request that we erase your personal data in certain circumstances
- the right to request that we restrict our processing of your personal data in certain circumstances
- when we are processing on the grounds of legitimate interest, the right to object to the processing, meaning we must stop unless we have an overriding reason which will be communicated to you
- you also have the right not to be subject to decisions which are based solely on automated processing, unless e.g. sufficient suitable measures have been implemented to safeguard your rights, including the right to obtain human intervention as required.
If you would like to exercise any of these rights you may contact us via email at: DPO@fmo.nl. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
If you have any other concerns about how we handle your personal data or if you have a complaint, we would also like to hear about it so we can try to find a solution. You always have the right to lodge a complaint with the applicable data protection authority. For the Netherlands, this is the Autoriteit Persoonsgegevens (PO Box 93374 2509 AJ DEN HAAG).
6. How we update this privacy statement and how to contact us
FMO can change the privacy statement at any moment. We will make an announcement of these changes on our website. Older versions of our privacy statement will be stored in our archives. To view an older version of the privacy statement, please contact firstname.lastname@example.org.
Questions about this privacy statement can be directed to our Data Protection Officer: DPO@fmo.nl.
You can also reach us at the following address:
FMO - Financierings-Maatschappij voor Ontwikkelingslanden N.V.
Data Protection Officer/ Compliance department
Anna van Saksenlaan 71
2593 HW The Hague
Version December 2022