Connecting Ophthalmologists from Around the World to Achieve Eye Health for Everyone

ICO Privacy Policy

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Data protection and security are important to us, as is your trust in our services. The International Council of Ophthalmology (“ICO“, “we“, “us“) is committed to collect and process your personal data responsibly and in compliance with applicable data protection laws. We use the word “data” interchangeably with “personal data“.
This Online Privacy Notice describes what we do with your data when you use our website www.icoph.org, including any subsites thereof (collectively “website“, “websites“).
If you disclose data to us or share data with us about other individuals, we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure to inform these individuals about this Privacy Notice.
This Privacy Notice is in alignment with the EU General Data Protection Regulation (“GDPR“), the Swiss Data Protection Act (“DPA“) and the revised Swiss Data Protection Act (“revDPA“). However, the application of these laws depends on each individual case.

1. Who is the controller for processing your data?

In general, the ICO is the sole controller under this Privacy Notice. Additional parties may be joint controllers for the processing set out hereinafter if they participate in determining the purpose or means of the processing.
If you have any questions or concerns, you may contact us by email to icoadmin@icoph.org or by mail to:
International Council of Ophthalmology
Rue de Lyon 77
CH-1203 Geneva, Switzerland

2. What categories of data do we process?

We process various categories of data. The main categories are the following:

    • Technical data: You can visit our websites and obtain information about our services without telling us who you are. However, when you use our website, we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of our websites. This data includes logs with records of the use of our systems. We generally keep data for around six months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 10). Technical data as such does not permit us to draw conclusions about your identity. Technical data may be linked to other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.
    • Registration data: You may interact with registration, subscription, or application forms on our websites (e.g., for ICO events, newsletters, educational programs, examinations, application for fellowships, or to access certain resources and journals or the ICO Portal). In that case, we will collect the data that you provide to us and data about the use of such services. We generally keep registration data for twelve months from the date the user account is closed or the use of the service ceases.
    • Master data: This is data that that we need, in addition to contract data (see below), for the performance of our contractual relationships or for marketing and informational purposes (e.g., invitations and newsletters). This may include data such as your name and contact details including your address, your date of birth, information about your professional qualifications, positions, the organization you work for and memberships as well as your bank and payment details to process payments. Where necessary for application purposes, we may ask you to provide data such as your photo and/or ID-copies.
      We generally keep master data for ten years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the retention period is usually much shorter, generally no more than two years from the last contact.
    • Contract data: We collect this data in relation to the conclusion or performance of contracts. This may include information about the contracts and the services provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing the contract or service, and information about feedback concerning a service.
      We generally keep this data for ten years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.
    • Communication data: When you are in contact with us via our websites by e-mail or other means of communication, we collect the data exchanged between you and us, including your contact details (such as master data, see above) and the metadata of the communication.
      We generally keep this data for twelve months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails and written correspondence are mostly kept for at least ten years.
    • Behavioral and preference data: In order to optimize your experience on our websites, we collect and process data about your behavior and preferences. We do so by evaluating information about your behavior on our websites, and we may also supplement this information with third-party information, including from public sources. Based on this data, we can for example determine the likelihood that you will use certain services or behave in a certain way. The data processed for this purpose is already known to us (for example where and when you use our services), or we collect it by analyzing your behavior (for example how you navigate our websites). We anonymize or delete this data when it is no longer relevant for the purposes pursued, usually around twenty-four months. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our website in Section 10.

 

In most cases, you provide the data set out in this Section to us. You are not obliged or required to disclose data except in certain cases, for example within the framework of legal obligations.

If you wish to enter into contracts with us or gain access to certain services and contents of our websites, you must also provide us with certain data, in particular master data, contract data and registration data. When using our websites, the processing of technical data is unavoidable.
As far as it is not unlawful, we may also collect data from public sources (for example the media or the internet, including social media) or receive data from other organizations that, e.g., are members of or close to the ICO, from public authorities and from other third parties (such as other medical organizations, contractual partners, internet analytics services, etc.).

The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we receive in relation to administrative and legal proceedings, information in relation to your professional functions and activities, information about you in correspondence and meetings with third parties, credit information (where we conduct business with you in a personal capacity), information about you that persons associated with you share with us so that we can conclude or perform contracts with you or involving you (for example references, your delivery address)

3. For what purposes do we process your data?

We process your data for the purposes explained below. These purposes and their objectives represent interests of us and potentially interests of third parties.
We process your data for purposes related to communication, in particular in relation to contacting or responding to you in case of queries. For this purpose, we use communication data and master data, as well as registration data in relation to services that you use based on prior registration. We keep this data to document our communication with you, for quality assurance and for follow-up inquiries.
We process data for the conclusion, administration, and performance of contractual relationships, especially contract data, communication data and master data. As part of performing contractual relationships, we may include involving third parties such as payment providers and other organizations that are members of or close to the ICO.
We process data for marketing purposes and relationship management, for example to send you newsletters and other informational communications on events etc., as well as the general management of ICO Memberships and registered users of our websites. For these purposes, we mostly process master data, communication data, contact data and registration data.
We process data for the purpose of regulatory compliance as well as the optimization of our internal processes such as risk management, corporate governance, and further administrative purposes (e.g., management of our IT infrastructure). Further purposes may apply. These further purposes include safeguarding other applicable legitimate interests.

4. On what basis do we process your data?

Where we ask for your consent to our processing activities, we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us notice by sending an e-mail to us. Where you have a user account, you may also withdraw consent or contact us through the relevant website and contact address thereof. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent, e.g. association or employer) or on our or a third-party’s legitimate interest in the particular processing. In particular, pursuant of the processing purposes as set out in Section 3 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA and the revDPA, Swiss law).

Where we receive sensitive personal data (for example health data or biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. Where another legal basis applies, we will communicate to you separately as necessary.

5. With whom do we share your data?

In relation to our websites and the services offered on them, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 3, we may disclose your personal data to third parties in Switzerland and abroad in certain scenarios. These third parties process your data on our behalf or as joint controllers with us or receive data about you from us as separate controllers.

These third parties may be organizations within the ICO, organizations we partner with in the context of our educational services, exams and fellowships (e.g., foundations, examiners and academic institutions) as well as service providers, e.g., IT providers, payment services and event managers.

We may disclose personal data to the authorities, i.e. agencies, courts, etc. in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests.

In cases that follow from the processing purposes set out in Section 3, we may interact with other third parties, such as references provided by you.

All these categories of recipients may involve third parties, and your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

6. Do we disclose your personal data abroad?

As explained in Section 5 above, we disclose data to other parties. These are not all located in Switzerland or Europe. Furthermore, we may process data in any other country in the world in certain cases.
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection. For this purpose, we use the revised European Commission’s standard contractual clauses, unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

7. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 2. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

8. How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

9. What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:
– The right to request information from us as to whether and what data we process from you;
– The right to have us correct data if it is inaccurate;
– The right to request erasure of data;
– The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
– The right to withdraw consent, where our processing is based on your consent;
– The right to receive, upon request, further information that is helpful for the exercise of these rights.
If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, or by e-mail according to our contact details in Section 1. In order for us to be able to prevent misuse, we will need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
If you do not agree with the way, we handle your rights or with our data protection practices, please let us know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country.

10. How do we use online tracking techniques?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits.
To ensure the functionality of the website, we wish to distinguish access by you (through your system) from access by other users. We do not intend to determine your identity, even where possible for us or third parties hired by us by combining tracking information with different data categories. However, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (a so-called “cookie”).
We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):
Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to twenty-four months.
Performance cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. Performance cookies also have an expiration date of up to twenty-four months. Details can be found on the websites of the third-party providers.
Depending on the purpose of these technologies, we may ask for consent before they are used. You can set your browser to block, deceive or delete certain types of cookies or alternative technologies. You can also add software to your browser that blocks certain third-party tracking.
One of the services we use is Google Analytics, provided by Google Ireland Ltd. (located in Ireland) which acts as our processor. Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both “Google“). Google collects information about the behavior of visitors to our website (duration, page views, geographic region of access, etc.) by using cookies and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are shortened by Google in Europe before forwarding them to the United States. Thereby, they cannot be traced back. We have turned off the “Data sharing” option and the “Signals” option. Although we can assume that the information we share with Google is not personal data for Google, it may be possible for Google to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries, where it may be accessible to authorities not subject to adequate privacy protections. Information about data protection with Google Analytics can be found here  and if you have a Google account, you can find more details about Google’s processing here .

11. What data do we process on our social network pages?

We may operate pages and other online presences on social networks and other platforms operated by third parties (such as Facebook, Twitter, Instagram, YouTube and LinkedIn) and collect data about you. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you. They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you). To that end, they act as separate controllers.
Certain pages of our websites contain social plugins (hereinafter “plugins“). The plugins are marked with a logo or a text note. When users call up a page of our website that contains such a plugin, the user’s browser establishes a direct connection with the networks’ servers. The networks transmit the content of the plugin directly to the browsers, which integrate them into the websites. If users are logged into one of the networks, it is possible that the networks assign the visit to their account to the corresponding network. When users interact with the plugins, the browser transmits the corresponding information to the networks. The networks then assign the information to the corresponding account.
For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other rights and how you can exercise them.

12. Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

Last update: [30 Dec 2022]

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