La Asociación Española de Microinmunoterapia (AEMI), L’Institut IFMi, Institut Français de Micro-immunothérapie (IFMI) and MEGEMIT – Medizinische Gesellschaft für Mikroimmuntherapie (collectively the Associations), are committed to ensuring the privacy of the visitors and users of the website https://www.icomi.org/ and to process their personal data pursuant to all applicable data protection laws and regulations including without limitation the General Data Protection Regulation EU 2016/679 (GDPR)
AEMI has a service contract with Kenes Group Spain, S.L. (Kenes) for the management of this website and the processing of participants’ data. Kenes, including its subsidiaries and affiliates worldwide (“Kenes”, “we”, “our” or “us”), puts great efforts in making sure that the personal data they process is safe and used properly, and that their data practices are properly communicated to our partners and participants.
I. Data processing for the management of Congress registrations:
(i) Participant data concerning our website visitors and/or event participants, attendees, lecturers and speakers (collectively, “Participants”), who register for events and/or webinars and/or online courses that we organize or take part in (collectively “Events”) and who visit or engage with our websites (such as https://www.icomi.org and their subdomains), our apps, blogs, message boards, chat rooms or other similar forums, online ads and content, emails or other communications under our control (collectively, the “Sites”); (“Events”).
(ii) Partner data concerning our partners and/or customers, sponsors, exhibitioners and association societies and their representatives (collectively “Partners”) who use Kenes’s event management platform and services or who otherwise cooperate with Kenes in organizing, promoting and executing the Events (together with the Sites and Events – the “Services”).
- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Roles and Responsibilities
- Additional Information and Contact Details
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Partners, or Service Providers (per Section 5 below), please avoid any interaction with us or any use of our Services.
1. Data Collection
Kenes process data regarding our Participants and Partners (“you” or “your”). Such data is typically collected and generated through automatic means, directly from you, through your interaction with us or with our Services; through our Partners or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives.
(i) Participant’s data:
- Participant account information: registration number, e-mail address, year of birth, profile picture, any comments on blogs, message boards, chat rooms or other similar forums, preferred language, networking preferences, professional interests and event schedule, and hashed password or other information used for authentication and access control (if applicable); Participants who attend as speakers may also provide their pictures.
- Participant contact information: full name, mobile phone number, address, company name, address and VAT number (if applicable), and additional information submitted by the Participant and/or their organization, or by our Partners;
- Participant registration information: educational, employment and professional background such as title, license, role and industry, professional expertise, abstract, documentation or proof of your professional status (if required for a special fee), and when applicable travel grant request and accessibility and dietary requirements.
- Other information: If you are a speaker or a lecturer then please note that additional information may be processed such as the content of your lecture. You may also be recorded during the event in which you participate.
(ii) Partner’s Data:
- Partner contact information: name, title, company, e-mail address, phone number, picture, and additional information submitted by the Partner and/or or their organization;
(iii) Additional Data collected across Participants and Partners
- Usage information: connectivity, technical and aggregated usage data such as, IP addresses, geolocation, device data (such as type, OS, device id, browser version, locale and language settings used), performance and activity logs, session recordings, activity on our Services, and the cookies and pixels installed or utilized on your device. When presenting your badge at an event, your physical presence may also be recorded and the personal data contained therein may be processed.
- Direct interactions and communications with us: this information usually include chats, surveys, feedbacks, recordings and transcripts of your calls, and other information you provide to us, including correspondence with us (e.g., for user experience, support and training purposes and any other data you upload);
2. Data Uses
Kenes processes the personal data described in Section 1 as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services. These include understanding how our Services are used, and how our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use your data for the following purposes:
- to facilitate, operate, activate, and provide our Services, including determining your initial and continued eligibility to use our Services;
- to authenticate your identity and allow you to access and use our Services;
- to process your activities such as event registration, abstract submission, attendance and accreditations;
- to provide you with customer care, assistance and technical support services;
- to further develop, customize and improve the Services, and to improve your user experience, based on common or personal preferences, experiences and difficulties;
- to facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
- to contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 7 below, and to facilitate, sponsor and offer certain events and promotions;
- to support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- to create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our Partners may use to provide and improve our respective services, or for any other purpose (such as estimating and reporting total audience size and traffic);
- to comply with our legal, regulatory, compliance and contractual obligations; and
- as otherwise described to you at the point of collection.
3. Data Location
We and our authorized Service Providers (per Section 5 below) maintain, store and process personal data in the United States, the EU, Israel, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
For a full list of Kenes’s locations, please click here.
4. Data Retention
We retain your personal data for as long as it is reasonably necessary to provide our Services; to maintain and expand our relationship and provide you with our Services and offerings; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations, and where applicable, also with our Partner’s reasonable instructions and as further stipulated in our Data Processing Addendum (DPA) and other commercial agreements with such Partner.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at email@example.com.
5. Data Sharing
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Service Providers: we may engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, hotel and venue providers and on-site contractors, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, and our business, legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.
Sharing Data with our Partners and their representatives: Participants’ data is shared with the administrator or other representatives of the relevant Partner, meaning, such representatives may access it on behalf of the Partner, and will be able to monitor, process and analyze the personal data contained therein. Please note that Kenes is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of such Partner, that itself also acts as the Data Controller of such data (as further described in Section 10 below).
Sharing Data with other Participants: registration and participation in our Events is only allowed for identified Participants (i.e., no anonymous participation is allowed). By participating in any of these Events you are required to identify yourself to us and to the other Participants, by name and country of origin or company. These details will be visible to other registered attendees in both physical and online events.
Sharing Public Information: we may share information that you voluntarily make public, including information that you post on any blogs, message boards, chat rooms, educational portals or other similar forumswhether or not such forums are operated or owned by Kenes. Since such public information can be accessed by others and used by any member of the public, such use by third parties is beyond our control. With your consent, we may also display personal testimonials of satisfied Partners on the Event website in along with your name.
Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Kenes, any of our Partners, their representatives, our Participants, or any members of the general public.
Additional Sharing: Kenes may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
6. Cookies and Tracking Technologies
Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, payment issues, login attempts or password reset instructions, etc. Our Partners may also use our Services to send the relevant Participants, messages and other updates regarding your use of the Services.
Notifications and Promotional Communications: we may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive promotional communications, you may notify Kenes by sending an e-mail to: firstname.lastname@example.org.
8. Data Security
We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. When personal information is transferred to us over the Internet, we encrypt it using Transfer Layer Security (TLS) encryption technology or similar technology. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
9. Data Subject Rights
Individuals have rights concerning their personal data any applicable law, including the EU General Data Protection Regulation (GDPR), or the California Consumer Privacy Act (CCPA). such rights include the right to request access, rectification or erasure of your personal data held with Kenes, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority. If you wish to exercise any of these rights please contact us by e-mail at: email@example.com.
Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
10. Roles and Responsibilities
Certain data protection laws and regulations, such as the GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” or “Business”, who determines the purposes and means of processing; and the “Data Processor” or “Service Provider”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Kenes is a Data Controller with respect to our Partner’s and their representatives’ data. Such data is processed by Kenes for our own purposes (as described in Section 2 above), as an independent Data Controller.
For the avoidance of doubt, each Partner, as an independent Data Controller, is responsible for the security, integrity and authorized use of their representatives’ and Participants’ information, for providing adequate notice to their representatives and Participants whose personal data may be processed – including sufficient reference to the processing of their personal data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Information and Contact Details
Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at firstname.lastname@example.org.
EU Representative: Kenes Spain has been designated as Kenes’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Kenes Spain may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to email@example.com.
II. Processing of data of persons who have agreed to receive information from the Associations
The Associations takes appropriate technical and organizational measures to ensure a level of security appropriate to the risk for the rights and freedoms of natural persons, including measures to protect Personal Data from an accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data.
For the purposes of EU data protection laws, the Data Controller, i.e. the responsible for, and which controls the processing of, your Personal Data are:
Asociación Española de Microinmunoterapia (AEMI) with registered office at Portal de l’Àngel 36, 08002 Barcelona, Spain.
Institut IFMi, Institut Français de Micro-immunothérapie with registered office at 18 rue Georges Clémenceau, 85700 POUZAUGES, France.
MEGEMIT – Medizinische Gesellschaft für Mikroimmuntherapie with registered office at SPACES/Gertrude-Fröhlich-Sandner-Str. 2, Tower 9, 1100 Vienna, Austria.
Purposes and legal basis of the processing activities et storage of your personal data
|Send information about Association’s activities and the micro-inmunothérapie||Consent of the website’s visitors||The time required for the purpose of the processing|
As a data subject, you have the possibility to request the exercise of the following rights:
- Right of access: you have the right to obtain confirmation as to whether or not your personal data is being processed and, if so, precise information as to the processing of your data. You also have the right to request a copy of the information held about you.
- Right to rectification: you have the right to ask us to rectify, in particular by completing or correcting, all or part of the information held about you.
- Right to erasure (“right to forgotten”): you have the right to ask us to remove all information held about you from our systems.
- Right to restriction of processing: you have the right to ask us not to process some of your data in certain circumstances. This is known as blocking.
- Right to data portability: you can ask to receive your information in a structured, commonly used and machine-readable format and transmit those data to another controller.
- Right to object: you can object to the processing of your personal data.
The application of these rights is not absolute. The requests of the exercise of rights will always be subject to a case-by-case analysis by the Responsible for the Data Protection of the Associations.
Where the processing of your data is based on your consent, you can withdraw your consent at any time, in a simple manner and without any justification.
If you want to have more information regarding the processing of your personal data or if you want to exercise your rights, your requests can be sent to firstname.lastname@example.org
You also have the right to lodge a complaint with the Data Protection Authority in the EU Member State of your habitual residence, place of work, or place of the alleged offence if you believe that your personal data is not being processed in accordance with the GDPR.
You will find the contact details of the different Data Protection Authorities at the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
III. Processing of data of persons who have agreed to the transfer of data to sponsors
If you have agreed to your data being transferred to the sponsors participating in the Congress, you can exercise your rights by sending an email to email@example.com or by contacting directly to the sponsors.
Please note that AEMI will do its best to deal with your request with the sponsor, but that it is the sponsor who is responsible for the processing of your data, once you have accepted the transfer.
Below you will find the list of sponsors and their contact details:
Effective Date: 5/07/2021