This Privacy Policy Addendum supplements the Privacy Policy at emeritus.org and describes additional rights of residents of the EU under the General Data Protection Regulation 2016/679 (the “GDPR”).
Capitalized terms not defined in this section shall be as defined in GDPR or in the Privacy Policy, as applicable.
GDPR provides certain rights for EU residents.
Storage and Retention of your Personal Data. We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected such data, including for legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like more information on this process, please do not hesitate to reach out to us at privacy@emeritus.org.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your partnership with us.
In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your Rights as a Data Subject.
By law, in certain circumstances, you have the right to:
- Request access to your Personal Data (commonly known as a “data subject access request”) to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you to ensure its accuracy and completeness.
- Request erasure of your Personal Data where there is no good reason for us continuing to process it and ask for deletion or removal of your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data.
- Request the transfer of your Personal Data to another party.
If you want to review, verify, correct, or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact us at privacy@emeritus.org.
What We May Need From You
We may ask for additional information to confirm your identity to ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
No Fee Usually Required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights) unless your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Your Right to Withdraw Consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You have the right to withdraw consent to marketing by following the opt-out links on any marketing message. To withdraw your consent for another circumstance, please contact us at privacy@emeritus.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Site or the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal and does not prevent the processing of Personal Data in reliance upon any other available legal bases). Requests should be submitted by contacting us by writing to privacy@emeritus.org (and you must state “Privacy Policy” as the subject matter of the enquiry in the subject line).
While you have the right to make a complaint at any time to the EU Supervisory Authority for data protection issues (www.ico.org.uk), we would, however, welcome the opportunity to address discuss and resolve concerns before you reach out to the EU Supervisory Authority so please contact us in the first instance.
General Data Protection Regulation (GDPR)
Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), Emeritus Institute of Management Pte Ltd. has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. EU residents can contact EDPO regarding matters pertaining to the GDPR as follows:
By email: privacy@edpo.brussels,
By using EDPO’s online request form
By mail to EDPO: Avenue Huart Hamoir 71, 1030 Brussels, Belgium.