ETI – Website Privacy Notice
This website is owned and operated by Equipment and Tool Institute (“ETI US“) and ETI Europe Limited (“ETI UK“, and together with ETI US, “ETI“, “we“, “us“, “our“). If you are located in the United States, ETI US is generally responsible for the processing of your personal data as described below. Otherwise, ETI UK is the controller of personal data collected from or about individuals within the scope of this privacy notice (“Notice“). ETI UK is registered with the Information Commissioner’s Office (ICO) (registration number: ZB778890).
This Notice informs you about how we process your personal data, in accordance with applicable data protection laws, including (as relevant) the UK and EU GDPR. This Notice covers users of our website, https://etools.org/ (“Website“), employees and other personnel of our members and prospective members, suppliers, vendors and other business partners, as well as marketing recipients, event attendees, employees and other personnel of vehicle manufacturers and individuals who otherwise communicate or interact with us.
Please read this Notice carefully, together with any other privacy notice or fair processing information that we may provide on specific occasions when we are collecting or processing personal data about you, to ensure that you understand how we may process your personal data and, where applicable, your rights under data protection laws.
If you have any questions about this Notice or how we use your personal data, please contact us using the information in the ‘Contact us’ section below.
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About this Notice
This Notice applies to information that we collect when you engage with us directly, including:
- through your use of the Website;
- when your employer or organisation is a member or applies to be a member of ETI;
- when you sign up to or otherwise attend one of our events (whether as an attendee, presenter, moderator, panellist or otherwise);
- when you sign up to receive marketing communications from us;
- when you communicate with us, either through the Website, by email, telephone or otherwise; and
- when you otherwise interact or communicate with us in the ordinary course of our or your business (including where you are a representative of a business partner, or an employee of a vehicle manufacturer, vendor or supplier).
This Notice also applies to information that we collect about you from sources other than directly from you, including where we receive your information from an appointed agent, from your employing organisation, [from another member] or where technical information is collected from the device used to access the Website.
To help us ensure we are being as transparent and accurate as possible, we keep this Notice under regular review. As a result, we reserve the right to change this Notice or create additional policies or notices to take account of changed circumstances or new legal requirements. As a result, we ask that you check back here on a regular basis and read this Notice together with any other privacy policies or notices that we have provided to you on specific occasions. If required, we will notify you of any material change we make to this Notice.
It is also important that the information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example if your name or contact details change.
The personal data we process and our legal basis
We collect and process your personal data for different reasons in different circumstances, provided that, where required by applicable data protection laws, we have a legal basis for doing so. Our purposes and, where required, legal bases for processing your personal data are set out in the table below:
Data | Purposes | Legal Basis |
Website Users | ||
Technical data, including IP addresses, browser types, computer, locations and connection information, and device identifiers. |
| Necessary for our legitimate interests in making improvements to our Website, keeping our Website secure, carrying out analyses of the use of our Website to assist us with promoting our services and running our business. Necessary to comply with a legal obligation. Your consent, where required and obtained. |
Members and Prospective Members | ||
Corporate contact information and details, including names, titles, postal addresses, telephone numbers and email addresses. Professional or employment-related information, including roles/titles and employer details. Other identifiers, including gender, nationality and correspondence records. Products/services data, including details about products/services supplied/used and payments, and identification data (e.g. usernames, passwords and other account credentials). |
| Necessary for our legitimate interests in effectively operating and administering our business and, where applicable, as otherwise described in the ‘Additional uses of data and legitimate interests‘ section below. |
Event Attendees, Prospective Attendees, Guests and Emergency Contacts | ||
Corporate contact information and details, including names, titles, postal addresses, telephone numbers and email addresses. Professional or employment-related information, including roles/titles and employer details. Other identifiers, including gender, nationality and correspondence records. Payment information. Visual information, including signatures. If applicable, details of any dietary restrictions/ preferences. |
| Necessary for our legitimate interests in effectively operating and administering our business, including planning, managing and running our events and, where applicable, as otherwise described in the ‘Additional uses of data and legitimate interests‘ section below. |
If applicable, photographs of attendees taken during events. |
| Necessary for our legitimate interests in promoting our business, including making publicising our events, including by running and posting via our social media accounts and, where applicable, as otherwise described in the ‘Additional uses of data and legitimate interests‘ section below. |
Guest information, including name and contact details. |
| Necessary for our legitimate interests in effectively operating and administering our business, including planning, managing and running our events and, where applicable, as otherwise described in the ‘Additional uses of data and legitimate interests‘ section below. |
Emergency contact information, including name and phone number. |
| Necessary for our legitimate interests in ensuring that we can contact the right person and necessary for the interests of the contact to be informed in case of an emergency. |
Marketing Recipients | ||
Corporate contact information and details, including names, titles, postal addresses, telephone numbers and email addresses. Professional or employment-related information, including roles/titles and employer details. Other identifiers, including gender, nationality and correspondence records. |
| Necessary for our legitimate interests in promoting our business, including membership services and our events and, where applicable, as otherwise described in the ‘Additional uses of data and legitimate interests‘ section below. Your consent, where required and obtained. |
Suppliers’ and Vendors’ Employees or Representatives | ||
Corporate contact information and details, including names, titles, postal addresses, telephone numbers and email addresses. Professional or employment-related information, including roles/titles and employer details. Other identifiers, including gender, nationality and correspondence records. Products/services data, including details about products/services supplied/used and payments. |
| Necessary for our legitimate interests in procuring or purchasing products and services, including making payments, arranging for supply and/or deliveries, generally for the purposes of dealing with our suppliers and, where applicable, as otherwise described in the ‘Additional uses of data and legitimate interests‘ section below. |
Correspondents and complainants | ||
Corporate or personal contact information and details, including names, titles, postal addresses, telephone numbers and email addresses. Professional or employment-related information, including roles/titles and employer details. Other identifiers, including industry subject, interests, gender, nationality and correspondence records. |
| Necessary for our legitimate interests in running our business, responding to enquiries, dealing with any legal claims that we wish to establish, exercise or defend against and, where applicable, as otherwise described in the ‘Additional uses of data and legitimate interests‘ section below. |
Additional uses of data and legitimate interests
We may rely on our (or a third party’s) legitimate interests as the lawful basis for processing your personal data. Where we do so we will carry out a balancing exercise to ensure that such interests are not overridden by your interests, fundamental rights and freedoms. Aside from the legitimate interests and purposes set out in the table above, we may also process your personal data based on the following legitimate interests and purposes:
- operating our business, administering our services and managing member accounts;
- contacting you to respond to your requests, inquiries or complaints;
- processing and completing transactions you have requested, including, as applicable, processing payments and providing services;
- operating, managing and securing certain Website functionality;
- enabling you to register for our services;
- improving and optimizing our services and other products, including for the benefit of ETI, its users and members;
- conducting industry and market research, surveys, polls and similar inquiries to help us understand trends and member needs in order to improve our services;
- ensuring the security of our systems and networks and to maintain the integrity of our IT systems and the continuity of our business;
- preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorised access to or use of personal data, our Website or data systems;
- establishing, exercising or defending legal claims; and
- enforcing our membership terms and other agreements.
Who we share your data with
We may share your personal data with the following third parties for the business purposes described above where it is fair and lawful to do so:
- our affiliates and group companies, such as ETI US and ETI UK, respectively. In such circumstances, your personal data will be processed in accordance with this Notice;
- our service providers or processors that we use for specific purposes, such as for our IT systems or software providers;
- our professional advisers, such as our lawyers, accountants and auditors;
- with your approval, other members, vehicle manufacturers and our business partners;
- where required to comply with applicable law or to establish, exercise or defend legal claims, regulatory authorities, public authorities, law enforcement agencies and courts, opposing or other related parties to the proceedings and their professional advisors; and/or
- in the event of a disposal or refinancing of all or a part of our business or assets, the prospective buyer or funder and their professional advisers.
International transfers of personal data
Some third parties with whom we share your personal data may be located outside of the UK, European Economic Area or the jurisdiction in which you reside. For example, ETI UK may transfer your personal data to ETI US and our service providers in the United States. The laws of some of these countries may not offer the same standard of protection for personal data as the jurisdiction in which you reside.
To the extent required by applicable data protection laws, we take steps to ensure that appropriate safeguards are in place to protect your personal data when it is transferred internationally. For example, by relying on an approved framework such as the EU-US Data Privacy Framework (and the UK Extension to the EU-US Data Privacy Framework) or by putting appropriate contractual agreements in place, such as the EU Commission’s Standard Contractual Clauses and the ICO’s UK Addendum. You can request more information on the safeguards we rely on or ask to obtain a copy of these by getting in touch with us using the contact details set out below.
Keeping your data safe and secure
We are committed to keeping your personal data secure and have implemented appropriate technical and organisational measures to protect your personal data from being accidentally or unlawfully destroyed, lost, altered, disclosed, used or accessed.
However, please note that despite our best efforts we cannot guarantee the security of information being exchanged over the internet and, where the Website contains links to other Website plug-ins and applications that are not operated by us, clicking on those links or enabling those connections may allow third parties to collect or share data about you. You should review these third parties’ privacy notices or policies for further information about how they process your personal data.
How long we keep your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, or as otherwise required for legal purposes. Once those purposes have been achieved then, unless a different purpose for processing your data arises, it will be anonymised or permanently deleted, subject to our standard data back-up procedures.
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. We also take into account legal and regulatory requirements which require the retention of personal data for a minimum period of time and applicable limitation periods in respect of legal claims.
Your rights in connection with your personal data
If our processing of your personal data is protected under the UK or EU GDPR, or certain other applicable data protection laws, you may have certain rights in in relation to your personal data. We have set out a list of rights that you may be entitled to below, although please note that they may not always apply in every case and may be subject to certain qualifications or otherwise only apply under certain conditions. If you reside in a jurisdiction where you are not provided rights relating to your personal data, or the data protection law in effect does not apply to us, we will consider providing you rights but do so at our own discretion.
- Access: you may have the right to obtain from us confirmation if your personal data is being processed by us in addition to certain related information, as well as the right to obtain a copy of your personal data undergoing the processing.
- Rectification: you may have the right to request the rectification of inaccurate personal data and to have incomplete data completed.
- Erasure: you may have the right to request that we erase your personal data in certain circumstances, such as if (i) our processing of your personal data is no longer necessary for the purposes for which we collected it, (ii) you have withdrawn your consent and no other legal ground for the processing applies, (iii) you objected and no overriding legitimate grounds for the processing exist, or (iv) the processing is unlawful, or erasure is required to comply with a legal obligation.
- Restriction: you may request that we restrict the processing of your personal data in certain cases, including where you object to us processing your personal data on the basis of our legitimate interests or where you want to establish the accuracy or the reason we are processing your personal data
- Objection: where we process your personal data on the basis of our legitimate interests, you may have the right to object to this processing for reasons relating to your particular situation. If this is the case, we will stop this processing of your personal data unless we can demonstrate compelling reasons why we need to process it which override your rights and freedoms, or where we need to process it for the purposes of legal claims.
- Portability: you may have the right to receive your personal data that you have provided to us, in a structured, commonly used and machine-readable format and to transmit it to other data controllers. This right only applies if the processing is based on your consent or where our processing of your personal data is necessary for the performance of (or to enter into) a contract with you and the processing is carried out by automated means.
- Right to refuse to provide information: you may have the right to refuse to provide information when requested, however please note that where the processing of that information is necessary for the purposes of entering into or performing contractual obligations, or to comply with our legal obligations, then your failure to provide certain information when requested could mean that we are unable to comply with those obligations.
- Right to refuse or withdraw consent: in cases we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your personal data that occurred prior to the withdrawal of your consent will not be affected.
To make a request to exercise any of these rights, please contact us using the information in the ‘Contact us’ section below. You will not usually have to pay a fee to exercise any of these rights. However, we reserve the right to charge a reasonable fee where permitted by applicable data protection laws, including if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances to the extent permitted by applicable data protection laws.
In certain circumstances, we may need to request specific information from you to help us confirm your identity before we comply with a request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If you appoint a third party to make a request on your behalf, we will require written proof from you that the third party is authorised to act on your behalf.
We do not discriminate against you, for example, by charging you a different price or offering a different level of service, for exercising any of these rights.
As above, the rights described above are not absolute and may not apply in certain circumstances. We reserve all of our rights available to us under applicable law in this regard.
[How we use cookies
Our Website uses cookies and other tracking technologies to help us make improvements to our Website and enhance your user experience. This can involve the collection and processing of your technical data as described above.
For further information about the types of cookies we use and why we use them, please read our Cookie Notice.]
Complaints
We would always welcome the chance to deal with your concerns in the first instance, but you may also have the right to make a complaint to a relevant data protection supervisory authority if you feel that we have handled your data improperly. The supervisory authority in the UK is the ICO; if you would like to contact the ICO, then you can do so through their website at https://ico.org.uk/.
Contact us
If you have any questions about this Notice or how we process your data then you can contact us at any time using the details below.
ETI US | ETI UK |
37899 W 12 Mile Rd Suite A-220 Farmington Mills MI 48331 United States of America | Squires Lodge 17 Main Street Nether Poppleton York, YO26 6HS United Kingdom |
Email: admin@etools.org
Last updated: 17th November 2024
