Privacy Notice

This Privacy Notice explains how and why we, the International Molybdenum Association, process any personal data we collect about you when you interact with us (including in those ways described in the “What personal data do we collect about you?” section below).

Our privacy practices reflect applicable legal requirements, including the General Data Protection Regulation, or GDPR (“Applicable Data Protection Laws”).

Please read this Privacy Notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your personal data. This Privacy Notice supplements the other notices and is not intended to override them.

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 relationship with us using the details set out in the “How To Contact Us” section below.

Please note, we reserve the right to amend this Privacy Notice at any time, normally by posting an updated Notice on our website and, where appropriate, notifying to you by e-mail.  Please check back frequently to see any updates or changes to this Privacy Notice.

Who we are
The International Molybdenum Association, registered as “association internationale sans but lucratif” or “AISBL”in Belgium (collectively referred to as the “IMOA”, “we”, “us” or “our” in this Privacy Notice ) is the controller responsible for the personal data we process about you in accordance with this Privacy Notice.

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out in the “How To Contact Us” section below.

What is personal data?
Personal data is information that relates to an identified or identifiable natural person, this means a human being. Anonymous information, where you cannot find out who the data relates to, is not personal data.

What personal data do we collect about you?
We may collect personal data about you when you:

  • register with us (including as a member);
  • access any newsletters, brochures, case studies, articles, videos and/or applications and other content on Our Sites (defined below);
  • make enquiries through Our Sites or via phone, fax, email, post or in person;
  • otherwise contact us.

This information may be collected either online or offline. We also monitor website usage and we may use cookies to collect information about your use of the website (see the “Cookies” section for further information below).

We may collect, use, store and transfer different kinds of personal data about you as set out below:

Information you give us: The information you give us may include your first name, surname, address, e-mail address, location, company title / position, employer and phone number.

Information we collect about you: With regard to each of your visits to our website, or other sites we control, we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website, and other sites we control, (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources: We may receive information about you if you use any of the other websites we operate or the other services we provide, or via trade or industry publications. We are also working closely with third parties (including, for example, business partners, third party cookies such as Google Analytics, consortiums, and committee members) and may receive information about you from them.

How will we use the information about you?
We use the personal data we collect about you to:

  1. manage our relationship with you or (where relevant) your employer;
  2. to communicate with you or (where relevant) your employer in response to enquiries;
  3. to provide you or (where relevant) your employer with information about the Association and our, services and publications (“Services”),
  4. to provide the Services to you or (where relevant) your employer on request, and to fulfil our obligations in respect of the same;
  5. to maintain and administer our website and any other online or social media channels, platforms or sites we operate (collectively, “Our Sites”), and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  6. to improve Our Sites, to ensure that content is presented in the most effective manner for you and for your computer or device;
  7. as part of our efforts to keep Our Sites safe and secure and to prevent fraud;
  8. to make suggestions and recommendations to you and other users of Our Sites about goods or services that may interest you or them; and
  9. to personalise your repeat visits to our website.

We may collect details about your use of Our Sites for the purposes of aggregate statistics or reporting purposes. Aggregated information (your data combined with other people’s data) may come from your personal data but provided it does not directly or indirectly reveal your identity, the aggregated information will not considered personal data for the purposes of this Privacy Notice. For example, we may combine and analyse your use of Our Sites to work out the number of users accessing a specific website feature. However, to the extent that the aggregated information could still be considered personal data, we will continue to process it in accordance with this Privacy Notice.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

(a) Where the processing is necessary for the performance of a request you have made (including a request for one of our Services);

(b) Where we need to comply with a legal or regulatory obligation, such as to meet accounting or reporting requirements or to contact Substance Information Exchange Forum (SIEF) members; or

(c) Where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Such legitimate interests may include:

  1. keeping you (or where relevant, your employer) up-to-date on the latest announcements, updates, developments, market analysis, regulatory compliance, statistical reports, bulletins and information in the molybdenum industry; and
  2. improving our member, and non-member, relations as well as enhancing and developing our Services, IT-systems and processes used to support our Services.

Please note that we may process your personal data using more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details set out in the “How To Contact Us” section below if you need details about the specific legal ground we are relying on to process your personal data on any given occasion.

Given the specific purposes for which we envisage using your personal data, under the provisions of Applicable Data Protection Law we do not anticipate being required to obtain your consent to do so, save for where we wish to use or share your personal data to provide you with marketing or information about products and services which may be of interest to you, and we are required by Applicable Data Protection Law to seek your consent before we do so. For more information on this please see the “Marketing” section below.

Should we wish to use your personal data for other specific purposes that require your consent, we will contact you to request this.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Data Protection Law.

Cookies
Like many websites, Our Sites may use ‘cookies’ from time to time. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. If you access our Sites or click-through an email we send you, a cookie may be downloaded onto your computer's hard drive. This information is used to track visitor use of the website and to compile statistical reports on website activity, and is not linked to any particular individual.

Cookies may also be used for other purposes on our website but in each case none of the information collected can be used to personally identify you. The default settings of browsers like Internet Explorer generally allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored.

You can set your browser not to accept all or some cookies or to alert you when websites set or access cookies. However, in a few cases some of our website features may not function if your browser is set not to accept cookies.

Disclosures of your personal data
We will not transfer, disclose, sell or distribute your personal data to third parties other than as set out in this Privacy Notice, unless we have your consent or are otherwise required or permitted to do so by Applicable Data Protection Law.

We may disclose your personal data:

  • to third parties as required for our every day business purposes, including to our related companies, our business partners, suppliers, sub-contractors, and technical services providers, including in order to provide you with the Services you request;
  • analytics and search engine providers that assist us in the improvement and optimisation of the Sites;
  • to competent authorities (including tax authorities), courts and bodies as required by law; or
  • to protect the rights, property, or safety of IMOA and our members and non members, or for internal investigations and reporting. This may include exchanging information with other companies and organisations for the purposes of fraud protection.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers
If we are required to transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

(b) We will undertake the transfer on the basis of a specific contract approved by the European Commission which give personal data the same protection it has in Europe (“Model Form Clauses”). For further details, and a copy of the text of these Model Form Clauses see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or

(c) Where we use service providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us using the details set out in the “How To Contact Us” section below if you want further information about the specific mechanisms we use when transferring your personal data outside of the EEA in a given circumstance.

Information security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

How long will you use my personal data for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any 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 unauthorised 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.

For further information as to any specific retention periods that might apply to personal data we hold about you, please contact us using the details set out in the “How to Contact Us” section.

In some circumstances you can ask us to delete your personal data: see the “Your Legal Rights” section below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. If we do that, we may use this information indefinitely without further notice to you.

Third party websites
Our Sites may contain links to other websites which are operated by third parties and not by IMOA. We are not responsible or liable for any content on these websites or for any interaction you have with them. This Privacy Notice only applies to our Sites so when you link to other websites you should read their own privacy notices.

Your Legal Rights

In certain circumstances, you have rights under Applicable Data Protection Laws in relation to your personal data. You may have the right to:

(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d) 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to exercise any of the rights set out above, please contact us using the details set out in the “How To Contact Us” section below.

Further rights are provided for in the Model Form Clauses referenced above.

These rights will be exercisable subject to the limitations set out above and as provided for in Applicable Data Protection Law. 

You may also have the right to lodge a complaint with your national data protection authority or other public authority governing the protection of your personal data in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by us infringes Applicable Data Protection Law. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

In addition, where you have provided (and we have relied upon) your consent to process your personal data, you may withdraw your consent, at any time by contacting us at the address stated below and where no other legal basis exist upon which we can process your data we will apply your preferences going forward. However this will not affect the lawfulness of any processing carried out before you withdrew your consent.

In some circumstances, withdrawing your consent or objecting to the processing of your personal data, or requesting its deletion, will mean that you cannot take advantage of certain of our Services or other opportunities, and we may need to suspend or terminate your access to such Services or Our Sites.

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). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you : We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to our Privacy Notice
We keep our Privacy Notice under regular review and we will place any updates on this webpage. This Privacy Notice was last updated on 25 May 2018.

How to contact us
Please contact us if you have any questions about our Privacy Notice or information we hold about you:

- by email: info@imoa.info
- or write to us at:

International Molybdenum Association
454-458 Chiswick High Road
London
W4 5TT
United Kingdom

Tel: + 44 (0) 20 8747 6120
Fax: + 44 (0) 20 8742 0128