Privacy Statement
1. Identity of the data controller
The European Federation of Public, Cooperative & Social Housing (hereafter “Housing Europe, “we”, “us”) is an international network of 42 national and regional federations, as well as 15 partnering organisations in 31 countries in Europe. Together they manage around 25 million homes, about 11% of existing dwellings in Europe.
As a not-for-profit organisation we unite public and social housing companies that share the ambition of improving professional practices and performances in the housing sector. This Privacy Statement therefore applies to the personal data that we process from you in the context of this activity.
Data protection and privacy are of a particularly high priority for us. We commit ourselves to process your personal data (hereafter your “data”) in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection rules applicable to Housing Europe. This Privacy Statement explains how we process your data and what rights you have in this regard.
Legally, Housing Europe is an international not-for-profit organisation, registered as a company in Belgium. You can find all our relevant details below. Via the mentioned contact details, you can always reach us for further questions or comments regarding the processing of your data by us.
Name and legal form:
The European Federation for Public, Cooperative and Social Housing
18, Square De Meeus
1050 – Ixelles, Brussels
BELGIUM
Registered office address:
Square de Meeûs 18
1050 Elsene (Brussels)
Belgium
Company registration number: 0473.324.762
E-mail address: communications@housingeurope.eu
2. What is the scope of application of this Privacy Statement?
This Privacy Statement is only applicable when Housing Europe is in charge of the processing of your data. This means that Housing Europe acts as data controller and determines why and how your data is being processed.
‘Processing’ means any kind of data processing that could identify you as a natural person. Which specific data this may concern, will be explained in detail below. The concept of ‘processing’ is broad and includes for example the collection, storage, disclosure and distribution of your data.
This Privacy Statement is applicable on the processing of data by Housing Europe from the categories of persons mentioned hereunder. For reasons of transparency and clarity, we will keep distinguishing between these categories of persons throughout the Privacy Statement, where relevant. Which data we process from you, the purposes for which we process your data, and other relevant elements are after all dependent on your relationship with EHousing Europe. The categories include persons who belonged to these categories in the past (e.g. former member), and persons who may belong to these categories in the future (e.g. potential future member).
- visitors of our public websites www.housingeurope.eu (hereafter the “Website”);
- our member and partner organisations, who assist us in the performance of our activities as an international housing network;
- candidate employees.
If one of the persons referred to above is a legal person, we still process data from our contact persons at these entities and the GDPR applies.
Our Website and Platform use cookies. For more detailed information about the processing of your data by the use of cookies on the Website and the Platform, please refer to our Cookie Statement, which forms an integral part of this Privacy Statement.
3. Which of your data do we process?
Below we clarify which data we can process from you. We do not necessarily process all data mentioned below from you. Which data we process in a specific case, depends on your specific situation, the way in which you contact us, and your preferences. For clarity, below we first of all clarify which data we may potentially process from all our contacts. We then clarify which data we additionally process for specific categories of contacts, in particular our members, business partners and candidate employees.
General
We may process the following data from all of our contacts:
– identification data: a copy of your ID card (solely for the verification of your identity should this be necessary in the context of privacy related requests);
– electronical identification and user data: including your browser type and version, operating system, IP address, location data, the date and time of access to the Website or Platform, your internet service provider, interactions with the Website or Platform, how you end up on the Website or Platform, the type of device you visit the Website or Platform with, the pages you visit, the way in which you navigate on these pages;
– contact details and contact history: your name, job title, postal address, email address, telephone number, mobile phone number, messages sent and received (e.g. e-mails you send to the e-mail addresses of Housing Europe as provided on the Website, or messages sent via the contact form on the Website).
Since we mainly rely on the use of cookies for processing the electronical identification and user data mentioned above, we refer to our Cookie Statement for more detailed information on this subject.
Housing Europe members
From the members of our international housing network, we may additionally process the data mentioned below:
– Platform registration details: username, password, first name, last name, address, city, state, zip code, country, day phone, cell phone, email address, company name, job title, Housing Europe role;
– Platform usage data: additional data you would actively provide via your personal account on the Platform, such as discussion posts, or any other content you would request to be published on the Platform (pictures, audio, video, …);
– data related to Housing Europe activities: our co-operation agreement and additional arrangements we may have, presentations, pictures and video recordings of our meetings together, details of events and programmes in which you participate as a Housing Europe member such as workshops and our CEO Academy, Junior Executive Academy and Exchange Programme;
– payment details: invoices, payment card details, bank account number;
– feedback: any feedback you may have, as a member, on our activities.
Candidate employees
From candidate employees, we may additionally process the data mentioned below. Naturally, this will largely depend on which information you wish to provide to us in the context of your application.
– Personal details: age, gender, date of birth, nationality.
– Work-related data: curriculum vitae, education, certificates and transcripts, language skills, professional career, publications, portfolio.
– Personality profile: motivation letter, hobbies, social activities, personality, job interview notes.
– Audiovisual data: pictures and video recordings that you would provide to us in the context of your application.
4. For which purposes and based upon which legal bases do we process your data?
We only process your data for legitimate purposes and based upon the legal bases that are listed in the General Data Protection Regulation (GDPR). Hereunder we clarify upon which legal bases we rely to process your data, depending on your relationship with Housing Europe.
For clarity, below we first provide an overview of the purposes and legal bases of the general data processing activities within our organisation. We then list the processing operations that are relevant to specific categories of contacts, in particular our members, business partners and candidate employees. Under each process, we have listed the legal basis in the sense of the GDPR, upon which we rely to process your personal data.
General
– answering your question when you contact us, when your contact request cannot be framed under an existing relationship with Housing Europe (such as the membership of your company of Housing Europe or the co-operation agreement you have with Housing Europe), via e-mail, via the contact form on our Website or in any other way;
- Legal basis: our legitimate interests
- offering you a Website that functions well on a technical level by the use of strictly necessary cookies, so that we can offer you a safe and well-functioning Website;
- Legal basis: our legitimate interests
- the use of analytical cookies on our Website to gain insight into how you use our Website, including with a view to detecting navigation problems, and to make the website more user-friendly and attractive;
- Legal basis: your consent
- the use of marketing cookies on our Website, for the purpose of displaying advertisements, implementing features on our website provided by social media, and measuring how often these advertisements and features are respectively displayed and used;
- Legal basis: your consent
- compliance with our legal obligations as a company, such as in the field of data protection and tax/accounting.
- Legal basis: legal obligation
- assuring the possibility of exercising or defending the interests of Housing Europe in court, if we believe that our interests are being harmed and that legal action is required, or if legal action would be taken against us by a person who feels disadvantaged by us;
- Legal basis: our legitimate interests
- the prevention, detection and investigation of fraud and abuse that would be made of our activities as an international housing network.
- Legal basis: our legitimate interests and those of our members
Housing Europe members
– fulfilling the pre-contractual and contractual obligations arising from the (potential) membership of your company of Housing Europe including managing our contractual relationship, informing you about our activities, terms and conditions and policies, providing you with the services resulting from your membership, invoicing your membership fee and obtaining payment thereof, and communication with your contacts at Housing Europe regarding your membership and the related services;
- Legal basis: the establishment or performance of our contract
- offering you, as our contact person for one of our members, the possibility to register a personal account to make use of the Platform, subject to manual verification by Housing Europe, as a way for members of our network to connect and interact with each other, and allowing you to make use of related functionalities and benefits, such as participating in (online) events, interacting with other members of Housing Europe, consulting presentations, pictures and video recordings of our meetings together, publishing additional data via this personal account such as discussion posts, sending personal messages to other users of the Platform and to receive such messages from other users, and notifying you about new content that is posted on the Platform by Housing Europe or other members;
- Legal basis: the performance of our contract, or our legitimate interests or those of our members where applicable, e.g. should no direct contract be in place between us
- offering you a Platform that functions well on a technical level by the use of strictly necessary cookies, so that we can offer you a safe and well-functioning Platform;
- Legal basis: our legitimate interests
- the use of analytical cookies on our Platform to gain insight into how you use our Platform, including with a view to detecting navigation problems, and to make the Platform more user-friendly and attractive;
- Legal basis: your consent
- making presentations and taking pictures and recording videos of our meetings together, in an online or offline context, for internal sharing within the network or for external publication should you agree to this;
- Legal basis: our legitimate interests, or your consent if you are specifically targeted in a picture or video, or for any external publications
- increasing our added value as international housing network, by requesting your valuable feedback on our activities as our current or former member, or examining your interest in activities we do not yet engage in with a view to potentially expanding our offering;
- Legal basis: our legitimate interests
- sending you newsletters with information about Housing Europe’s activities, through electronic channels or otherwise, that we believe may be of interest to you based on your existing relationship with Housing Europe as our member. You have an absolute right to object to the processing of your data for direct marketing purposes and to withdraw your consent where applicable. Regarding marketing material that we send to you by e-mail, you always have the option to unsubscribe via the unsubscribe link provided at the bottom of each such e-mail;
- Legal basis: our legitimate interests, or your consent where expressly requested
- checking your satisfaction as our member.
Candidate employees
- Legal basis: our legitimate interests, or your consent where expressly requested
- assessing whether Housing Europe wishes to enter into an employment, internship or co-operation agreement with you;
- Legal basis: the establishment of our contract
- keeping the information you provided us in the context of an application for a maximum period of 2 years, if you have an interesting profile, but we could not initially make a proposal because there was no suitable position available. Should a suitable position become available, we will use your details to contact you again and to gauge your interest in further discussions.
- Legal basis: your consent
5. When and why do we transfer your data to third parties?
General
We will not transfer your data to third parties, unless this is necessary for achieving one of the aforementioned purposes, you give your consent for such transfer, or we are required to do so by law.
Where necessary we engage external service providers, so called “data processors”, to support our operational purposes such as providing our services, managing our IT systems or performing any other (internal) business processes such as the digital storage of our member files. These external service providers may perform certain processing activities on your data on our behalf. We will only share your data with these external service providers to the extent necessary for the relevant purpose. The data may not be used for any other purposes by these third parties. In addition, these service providers are contractually bound to ensure the confidentiality of your data by means of a so-called “data processing agreement” concluded with these parties.
Identification of third parties to whom we may transfer your data
In concrete terms, this means that we may share your data, to the extent necessary as specified below, with the following third parties for the following purposes, with these third parties acting as data processors on our behalf in certain cases. Below each transfer, we have listed the legal basis in the sense of the GDPR, upon which we rely to transfer your data to these parties.
– postal, transport and delivery companies regarding your contact details for the purpose of sending mail to you as our current, former or future member or business partner, or as candidate employee;
– the processors who assist us in the IT field in operating our housing network, with the aim of efficient digital data management within our organisation, including the digital storage of our member files, the delivery of transactional e-mails such as invitations and guidelines for our members in connection with their membership of our organisation, or information with regard to the provision of the services we provide to you or you to us in the context of our relationship as business partners, the delivery of e-mails for the purpose of promoting the activities of Housing Europe, the hosting and management of the Website, Platform and our mailboxes, the support to Housing Europe in understanding