1. WHO ARE WE?
1.1 Your personal data is processed on the basis of applicable data protection legislation by the Church of Scientology International, 6331 Hollywood Boulevard, Los Angeles, CA 90028, United States of America (hereinafter: “CSI”, “we”, “us”, “our”). You can contact us via e-mail at email@example.com.
2. WHICH OF YOUR PERSONAL DATA DO WE PROCESS?
2.1 When you use our Website or our social media channels, we process:
2.2 When you communicate with us by filling out a contact form on our Website, or via e-mail, telephone, fax or social media channels, we process:
2.3 When you place an order, such as for a book or an information kit:
2.4 We receive most of your personal data directly from you, but it may happen that we receive additional information about your preferences and browsing behavior from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.
3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA AND WHAT IS THE LEGAL BASIS FOR THIS?
3.1 In the table below, we explain the purposes for which we process your personal data and on which legal basis we do so. We rely on the following legal bases:
|1.||We process your personal data to provide you, in a personalized and efficient way with the materials, services or information you request via our Website, e-mail, telephone, fax or social media channels.|| Our legitimate interest
A contract with you
|2.||We process your personal data in order to be able to process your order and to be able to deliver to you the materials or information you request or to provide you with the services you request.||A contract with you|
|3.||We process your personal data to send you promotional information for our materials and services, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels if you explicitly consented to receiving such promotional information.||Your consent|
|4.||We process your personal data to send you promotional information for materials or services similar to those you previously purchased or received from us, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels.||Our legitimate interest|
|5.||We process your personal data for other marketing purposes, such as on paper or via social media channels, i.e. to provide you with targeted promotional information, such as communications, promotions, offerings and newsletters of CSI and carefully selected partners.||Our legitimate interest|
|6.||In the framework of sending you promotional information, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels, we process your personal data to collect information to analyse our promotional information, such as which of our content in those promotional information you have accessed or on which links in those promotional information you have clicked (i.e.g. via tracking technologies such as web beacons in our e-mails).||Your consent|
|7.||We process your personal data to create a unique profile of you to enhance your experience based on your location, your order history, your preferences, your interests and the content in our promotional information you have accessed.||Your consent|
|8.|| We process your personal data:
||A legal obligation|
|9.||We process your personal data to perform statistical analyses in order to be able to improve our Website, promotional information, materials and services or to develop new materials and services.||Our legitimate interest|
|10.|| We process your personal data to preserve our legitimate interests or to preserve the legitimate interests of a third party in case your use of our Website, our social media channels or other communication channels can be considered:
||Our legitimate interest|
4. TO WHOM DO WE SEND YOUR PERSONAL DATA?
4.1 We rely on third parties, for example:
These third parties are only allowed to process your personal data on our behalf and upon our explicit written instruction. We also warrant that all those third parties are selected with due care and are committed to observing the safety and integrity of your personal data.
4.3 We may be legally obliged to share your personal data with competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities, to comply with a legal obligation as set out in Article 3.
4.4 We do not send your personal data in an identifiable manner to any other third party than the ones mentioned in Articles 4.1, 4.2, and 4.3 without your explicit consent to do so. However, we may send anonymized data to other organizations that may use those data for improving materials and services as well as to tailor the marketing, displaying and selling of those materials and services.
5. WHERE DO WE PROCESS YOUR PERSONAL DATA?
5.1 We process your personal data both within and outside the European Economic Area (EEA), including in the USA. In order to process your personal data for the purposes outlined in Article 3 above, we may also transfer your personal data to third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. For CSI, such safeguards result from the fact that we are directly bound by compliance with EU legislation in the context of personal data protection. For third parties, such safeguards may be the consequence of:
5.2 We may transfer anonymized and/or aggregated data to organizations outside the EEA. Should such transfer take place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.
6. WHAT QUALITY ASSURANCES DO WE COMPLY WITH?
6.1 We do our utmost best to process only those personal data which are necessary to achieve the purposes listed under Article 3.
6.2 Your personal data are only processed for as long as needed to achieve the purposes listed under Article 3 above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. We will de-identify your personal data when they are no longer necessary for the purposes outlined in Article 3 above, unless there is:
6.4 We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss tampering or destruction. Access by our staff members or third parties’ personnel will only be on a need-to-know basis and be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.
6.5 If you are registered to receive promotional information, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such promotional information by clicking the opt-out link provided in such promotional information.
7. WHAT ARE YOUR RIGHTS?
7.1 You have the right to request access to all personal data processed by us pertaining to you. We reserve the right to charge a reasonable administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request must specify for which processing activity you wish to exercise your right to access and must specify to which data categories you wish to gain access to.
7.2 You have the right to rectification, i.e. to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.
7.3 You have the right to withdraw your earlier given consent for processing of your personal data.
7.4 You have the right to erasure, i.e. to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against:
7.5 You have the right to restriction instead of deletion, i.e. to request that we limit the processing of your personal data if:
7.6 You have the right to object to the processing of personal data if:
However, if the intended processing qualifies as direct marketing, you have the right to object to such processing free of charge and without justification.
7.7 You have the right to data portability, i.e. to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us if the processing is based on your consent or a contract with you under Article 3 above.
7.8 If you wish to submit a request to exercise one or more of the rights listed above, you can contact our Data Protection Officer by sending an e-mail to firstname.lastname@example.org. An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should meet the following conditions:
We will promptly inform you of having received your request. If the request meets the conditions above and proves valid, we will honor it as soon as reasonably possible and at the latest thirty (30) days after having received your request.
If you have any complaints regarding the processing of your personal data by us, you may always contact our Data Protection Officer by sending an e-mail to email@example.com. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority.