ICC Dispute Resolution Learning Space
Privacy Policy
Data controller:
ICC Dispute Resolution Learning Space on https://drslearning.iccwbo.org/ is a platform for courses provided by the International Chamber of Commerce (“we” or “ICC”).
The ICC International Secretariat is located at 33-43 avenue du Président Wilson, 75116 Paris, France. We can be reached by phone at +33 1 49 53 28 28 or by email at icc@iccwbo.org.
The purpose of this Privacy Policy is to inform you of the procedures regarding the collection, use and disclosure of information on ICC Dispute Resolution Learning Space, including any mobile versions or related mobile applications, collectively called ICC Dispute Resolution Learning Space platform (hereafter the “Platform”). ICC encourages you to carefully read this Privacy Policy.
By visiting the Platform and providing information to ICC, you acknowledge that you have been informed and you consent to the Privacy Policy, including with regard to ICC’s use and disclosure of personal information which may be collected when you register for learning courses and other events in accordance with the purposes detailed below. If you do not wish your personal information to be used by ICC in the manner set out in this Privacy Policy, please do not provide us this information.
Topics:
- What data do we collect?
- How do we collect your data?
- How will we use your data?
- How do we store your data?
- Transfer of data
- Security
- What are your data protection rights?
- What are cookies?
- What types of cookies do we use?
- Privacy policies of other websites
- Updates to privacy policy
- How to contact us
- How to contact the appropriate authorities
- What data do we collect?
ICC collects the following data:
- Personal identification information (Name, email address, phone number, profile picture, curriculum vitae, cover letter, and job information.
- Log data: whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.
- How do we collect your data?
You directly provide most of the data we collect. We collect data and process data when you register online or place an order for any of our products or services.
We also collect information that you agree to provide when you:
- Complete a customer survey or provide feedback on any of our message boards or via email.
- Display your photo on the Platform.
- How will we use your data?
For the performance of the contract between you and us, we:
- Manage your account.
- Perform your order, including possible transfers to our processors: the trainers, Stripe for the payment, Law firms and ICC National Committees when they host sessions, Reply as provider of the Platform tool and AWS for the storage of data on the cloud.
- Contact you to provide information related to the courses, to reply to your questions and to have your feedback.
- Display your photo and a short bio on the platform to enable you to network with other trainees and possible professionals.
For the compliance with our legal obligations:
- Where necessary for the establishment, exercise or defence of legal claims of ICC and to meet our legal obligations including tax and compliance obligations pursuant to relevant local and international laws and regulations on fraud, corruption and money laundering and international financial sanctions and restrictive measures, as well as any other applicable legal obligations that may apply (“Legal Compliance Obligations”).
- Where necessary, sending your data to, and also using the resulting information from, credit reference agencies to prevent fraudulent purchases.
For marketing purposes, we:
- Would like to send you by email special offers on similar products and services provided by ICC, ICC affiliates, ICC National Committees and Groups, we think you might like.
At any tile, you will have the right to stop ICC from contacting you for marketing purposes or giving your data to affiliates.
If you no longer wish to be contacted for marketing purposes, please click here.
- Subject to your express agreement by ticking an opt in clause when you provide your personal data, ICC will share your data with our partner companies so that they may offer you their products and services. They may be:
- Other enrolees of the Platform
- Sponsoring organizations
- How do we store your data?
ICC securely stores your data on AWS at the Ireland (eu-west-1) datacenter, where the Platform infrastructure has been tested and hardened in order to secure data in the most efficient way possible, following 'least privilege' principles. All the best practices advised by AWS were taken into account when designing the Platform architecture. (
ICC undertakes to keep the collected personal data only for the time strictly necessary for the processing for the aforementioned purposes, and in any case, within the limits imposed by law.
Purposes |
Legal basis |
Retention period |
Using the account |
Contract |
5 years from the last usage |
Contracts with professionals or trainees |
Contract |
5 years or 10 years for orders over €120,00 |
Processing with orders |
Contract |
10 years |
Processing with deliveries |
Contract |
10 years |
Invoicing |
Contract |
10 years |
Complying with international sanctions obligations and preventing fraud, corruption and money laundering |
Legal |
5 years from alert registration |
Marketing and business development |
Consent |
3 years from the last activity |
Statistics |
Consent |
6 months |
Answering to any questions and/or inquiries |
Legitimate interest |
1 year |
Maintaining the unsubscription requests |
Legitimate interest |
3 years |
- Transfer of data
ICC never sells your personal data to third-parties. They are only used by competent services of ICC, for accounting operations for example, and by processors to perform functions on ICC behalf.
For the purposes mentioned in section 3, as a global organization, ICC may need to transfer and process your personal information in a country other than your country of residence and/or outside of the European Union, to/in countries which may have different data protection laws.
In this case, ICC will put in place appropriate and adequate operational, organizational, procedural, and technical measures in order to ensure the security and confidentiality of your personal data.
The processors are:
- AWS at the Ireland (eu-west-1) datacenter;
- Stripe, for payment, located in France. Data is stored in AWS in United States. Stripe have appropriate safeguards and compliance measures to ensure an adequate level of protection of personal data transferred outside the EEA and Switzerland. Stripe’s existing measures include the EU Commission’s approved Standard Contractual Clauses (SCCs) to accommodate international data transfers (details here);
- National authorities where required by law for preventing fraud, corruption and money laundering and complying with international sanctions;
- Certain Law firms or ICC National Committees when they host sessions.
- Security
Protecting your privacy and your personal information is a priority for ICC. ICC has taken reasonable measures to protect your personal information from loss, misuse and alteration. However, please be aware that no data transmission over the Internet or storage technology can be guaranteed to be 100% secure. ICC can only take steps to help reduce the risks of unauthorized access to information/data. Each individual using the Internet user can also take steps to help protect his/her personal information and is encouraged to do so to further minimize the likelihood that a security incident may occur.
- What are your data protection rights?
ICC would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access - You have the right to request ICC for copies of your personal data. We may charge you a small fee for this service.
The right to rectification - You have the right to request that ICC correct any information you believe is inaccurate. You also have the right to request ICC to complete information you believe is incomplete.
The right to erasure - You have the right to request that ICC erase your personal data, under certain conditions.
The right to restrict processing - You have the right to request that ICC restrict the processing of your personal data, under certain conditions.
The right to object to processing - You have the right to object to ICC’s processing of your personal data, under certain conditions.
The right to data portability - You have the right to request that ICC transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our Platform, we may collect information from you automatically through cookies or similar technology.
- What type of cookies?
Necessary Cookies
ICC collects only Necessary cookies. Those cookies are absolutely essential for the Platform to function properly. This category only includes cookies that ensures basic functionalities and security features of the Platform. These cookies do not store any personal information.
- Privacy policies of other websites
The Platform may contain links to other websites. Our privacy policy applies only to our Platform, so if you click on a link to another website, you should read their privacy policy.
- Updates to Privacy Policy
To the extent permitted by applicable law in your jurisdiction, ICC may, from time to time, revise or update this Privacy Policy. You agree to be bound by such modifications or updates. If we make material revisions to the way we collect or use your personal information such that we are using it for purposes that you have not consented to, we will notify you of the changes and, as the case may be, ask for your explicit consent.
Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Internet, accessible through the ICC Platform. By continuing to use the ICC Platforms following such changes, you will be deemed to have agreed to such changes.
- How to contact us
If you have any questions about the Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us or the Data Protection Officer, as follows:
ICC
33-43 avenue du Président Wilson
75116 Paris, France
Tel +33 1 49 53 28 28
Email icc@iccwbo.org
Data Protection Officer
33-43 avenue du Président Wilson
75116 Paris, France
Tel +33 1 49 53 29 05
Email: dataprotection@iccwbo.org
- How to contact the appropriate authority
Should you wish to report a complaint or if you feel that ICC has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner's Office on https://www.cnil.fr
Date: 21 July 2023