Date: 11 Jun 2024

This Privacy Policy is provided to ensure that persons whose personal data is being collected by Headquarters Supreme Allied Commander Transformation (HQ SACT), acting as Personal Data Controller (Controller), are informed about the management of their personal data when registering for an HQ SACT organized (or co-organized) event. For purposes of this Policy, “event” includes any conference, webinar, forum, seminar or workshop, whether taking place virtually or in-person.

Contact details of HQ SACT, acting as a Controller:

POC: 

HQ SACT Personal Data Protection Officer

Address: 

7857 Blandy Road Suite 100 Norfolk
VA 23551-2490

What personal data is collected by the HQ SACT:

Controller collects and processes the following personal information:

• Personal identifiers including names, nationality, and characteristics (civilian, military, rank, if necessary, age, gender, and contact details)

• Email address

• Working position

• Phone number

• Passport number (if needed to secure access to facilities)
• Date of birth (if needed to secure access to facilities)

How do we obtain the personal data and why do we have it:

The personal data Controller processes provided:

• Directly by you through our registration platform, when you register for events as defined above that HQ SACT is organising whether online, in person, or otherwise.

We do not collect, nor maintain special categories personal data, such as related to racial or ethnic origin, sexual orientation, political, philosophical, religious opinions or activities, as well as genetic, biometric data and data concerning health. If you provide any special categories of personal data to us, you consent to the collection and processing of this special categories of personal data by virtue of providing this information.

We collect personal data for any of the following reasons:

• In order to permit you to access the information on the event dedicated website you visit or grant you access to the requested event dedicated website;

• To administer the event dedicated website;

• To confirm your identity to prevent unauthorised access to event dedicated website;

• To deliver information on event dedicated website effectively, safely, and in quality manner;

• For our internal analytics purposes, we collect and use the personal data automatically collected through event dedicated website. Data automatically will be collected using cookies and similar tracking technology and will be only used for internal purposes.

• To communicate with participants regarding the specific event for which participant registered.

• For HQ SACT internal reporting purposes.

• As reasonably necessary for the management and organization of the specific event for which participant has registered.

• For any other purpose to which you consented in connection with the specific event.

• To provide sufficient information to the security services that will manage access to the facilities (if applicable)

We share your personal data under the following circumstances:

The HQ SACT may share collected personal data outside HQ SACT and its subordinate Commands in the following situations:

• With other NATO bodies to ensure proper functioning.

• With other members of the particular event as defined above and otherwise same community of interest.

• With co-organizers of the event as reasonably necessary for the management and organization of the specific event for which participant registered.

• With external service providers to ensure proper event management, such as supporting event management, IT system management, data storage and similar.

• If necessary and when in accordance with NATO policies, directives including national security.

Our basis for processing collected personal data:

HQ SACT relies on the following for processing collected personal data:

• Your consent. If you wish to remove your consent at any time, you can do this by sending an e-mail notification to the event organisers or deleting your account on the event dedicated website or otherwise contacting HQ SACT.

• ACT’s legitimate interest to communicate information about NATO activities, develop and improve our event dedicated website, maintain communication, organize event and protect NATO staff members, assets, and information.

Audio and Visual Recording; Live Streaming:

Photographs and/or filming and/or live-streamed will be taken during (part of) the event organised. By attending the event and by expressing it also with your behaviour you confirm consenting to and being aware that photographs and video (including voice) records may be taken at the event and published in NATO HQ SACT publications, media, in websites of NATO HQ SACT or other NATO bodies and other websites as well as on NATO HQ SACT accounts in social media for the purpose of NATO HQ SACT activities and event promotion purpose.

If you do not wish to be photographed, filmed or appear under these conditions, you should avoid filmed/photographed areas during the event or let the photographer/operator appointed by NATO HQ SACT understand that you do not wish to be photographed/filmed. NATO HQ SACT takes no responsibility for photo and/or video records made by the attendees of the NATO HQ SACT event for personal purposes and for their use or legality.

HQ SACT stores your personal data:

Your data is stored by the HQ SACT consistent with / as prescribed by NATO policies and procedures. We only store and retain personal data collected as described above and when needed for the purposes defined above. The HQ SACT will safely dispose of your data in line with NATO policies and procedures.

Your rights related to your personal data:

You can take the following actions concerning your personal data (or on behalf of certain family members such as young children):

• Obtain confirmation as to whether your personal data is being processed.

• Access your personal data, subject to further exceptions outlined.

• Rectify inaccurate or incomplete personal data or erase your personal data in case it is no longer necessary for the purpose it was collected or it was processed in a manner contradictory to the specific purpose. Names of any data subject acting in an official capacity from NATO information of permanent value shall not be deleted.

• Object to the processing if you believe that there is no legitimate basis for processing your personal data.

• Complain and appeal regarding HQ SACT’s decisions with regard to your personal data and any related requests.

Please be aware that following exceptions to the release of personal data apply:

• In case there is a possibility of adverse effect to the rights of others.

• There are possible violations of NATO policies on the release of classified or non-classified information;

• Due to ongoing inquiries, investigations or disciplinary proceedings.

• In case personal data is related to legal advice, used in litigation or deliberative proceedings;

• In case data is processed for the purpose of security, intelligence or counter-intelligence activities.

Personal data shall not be made available if to do so would involve disproportionate resources for HQ SACT, or would be impossible. In such cases, we shall provide access to the extent reasonable.

How to complain:

Please address your concerns to the HQ SACT by email at privacy@innovationhub-act.org

Further updates:

HQ SACT reserves the right to review and update this policy as needed. Please note the most current date indicated above.