1. Introduction

The Applied Neuroscience Association ("ANA," "we," "our," "us") is committed to compliance with applicable data protection laws in the United Kingdom (UK). This Privacy Policy outlines how we handle the personal data of users ("you," "your," "their") of the ANA website. For any privacy-related inquiries, you can reach us at datacontroller@appliedneuroscienceassociation.com.

 

Users are informed of the ANA Privacy Policy through our Cookie banner upon their first interaction with the website. The policy's "last updated" date is clearly displayed at the bottom of the page.

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2. Purposes of Processing

2.1 Online Purposes
Personal data collected through the website may be processed for the following purposes:

• Administering and maintaining the website.

• Providing support for website functionality and usage.

• Delivering personalised user experiences.

• Enabling access to services and features.

• Sending relevant communications and notifications.

• Conducting marketing activities, with explicit user consent.

• Performing anonymised statistical analysis to enhance and improve services.

2.2 Offline Purposes
Personal data collected through offline interactions may be processed for the following purposes:

• Maintaining engagement after in-person interactions.

• Sending tailored communications and notifications, upon consent.

• Providing event invitations, updates, and follow-up details.

 

3. The Recipients of the Personal Data

3.1 Hosting and Third-Party Applications
ANA is hosted on the Wix.com platform, which provides the online infrastructure for promoting our services. Your personal data may be stored through third-party applications interacting with our website, as well as Wix.com’s general applications, and Wix.com’s databases located globally. Wix.com ensures your data is stored securely on servers protected by firewalls. Please note that third-party applications have their own privacy policies, which we recommend you review.

3.2 Secure Payment Processing
All direct payment gateways provided by Wix.com and used by ANA comply with PCI-DSS (Payment Card Industry Data Security Standard), managed by the PCI Security Standards Council (comprising Visa, MasterCard, American Express, and Discover). These standards ensure the secure handling of credit card information by Wix.com and its associated service providers.

3.3 Responsibility for Passwords and Sensitive Data
Users are responsible for safeguarding their passwords and any "special category data" or sensitive personal data. ANA will never request access to passwords or sensitive personal data requiring heightened protection due to its sensitive nature.

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4. Legitimate Interests for Processing

4.1 Legitimate interests is one of the six lawful bases for processing personal data under Article 6(1)(f) of the UK GDPR. It permits processing when it is necessary for the purposes of the legitimate interests pursued by the data controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the user.

4.2 We process personal data under the legitimate interests basis in ways that individuals would reasonably expect and that have a minimal privacy impact. This includes managing memberships, facilitating communications, and conducting direct marketing activities. In each case, we ensure that our processing is proportionate, has a minimal privacy impact, and individuals would not be surprised or likely to object.

4.3 To apply the legitimate interests basis, we conduct a Legitimate Interests Assessment (LIA) and document it, which involves a three-part test:

1. Purpose Test: Identifying the legitimate interest(s) pursued.

2. Necessity Test: Determining whether the processing is necessary for the purpose(s).

3. Balancing Test: Assessing whether the individual's interests override the legitimate interest(s).

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5. Lawful Basis for the Processing

5.1 Legitimate Interests: ANA processes personal data when it is necessary for our legitimate interests, such as managing memberships and communications with members.

5.2 Consent: For specific activities, including marketing communications, we will obtain your clear and explicit consent. You have the right to withdraw this consent at any time.

5.3 Contractual Obligation: We process personal data when it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

5.4 Legal Obligation: In certain circumstances, we may process personal data to comply with a legal obligation to which ANA is subject.

Your Rights:

• You have the right to object to processing based on legitimate interests

• Right to Access: You have the right to request access to your personal data that we hold.

• Withdrawal of Consent: You have the right to withdraw your consent for processing your personal data at any time.

• Right to Erasure: You have the right to request that we delete your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where applicable).

• Right to Complain: You have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

 

6. Categories of Personal Data Obtained

6.1 Website Interaction Data

We utilise software tools and cookies to gather session information, including:

• Page response times

• Duration of visits to specific pages

• Page interaction details

This data helps us understand user engagement and improve website performance.

6.2 Transactional Information

When you perform transactions on our website, we collect personal information such as:

• Name

• Address

• Email address

This information is used solely for the purposes specified at the time of collection.

6.3 Technical Data

Depending on your cookie preferences, Wix.com may collect your Internet Protocol (IP) address to facilitate website functionality and security.

6.4 Voluntarily Provided Information

We collect personally identifiable information that you voluntarily provide, including:

• Member profiles

• Academic qualifications

This data is used to personalise your experience and provide relevant services.

6.5 Children's Data

We do not knowingly collect personal data from individuals under 13 years of age without verifiable parental consent. If we become aware that we have inadvertently collected such data, we will promptly delete it.

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7. Transfers of Personal Data to ANA Chapters

7.1 Centralised Data Collection
All member data is collected and managed by ANA Headquarters (HQ) in London. By centralising data management through ANA HQ while utilising secure global databases provided by Wix.com, who operate across various international locations, adhering to Wix.com’s privacy and security standards.

7.2 International Data Transfers
Under UK GDPR and Data Protection Act 2018, the storage and processing of personal data in global locations are considered international transfers. To ensure compliance, we understand WIX.com takes the following steps:

• Adequacy Decisions: Where applicable, data transfers occur to countries deemed adequate by the UK government for data protection.

• Appropriate Safeguards: In other cases, we implement safeguards such as the International Data Transfer Agreement (IDTA) or the Addendum to the EU Standard Contractual Clauses (SCCs) to protect personal data during transfers.

• Derogations: Where necessary, specific exemptions under the UK GDPR may be applied.

7.3 Responsibilities of ANA Chapters
While data management is centralised through ANA HQ, each ANA Chapter Founding Member are responsible for ensuring local compliance with data protection laws within their jurisdictions. This includes confirming that the use of ANA services and Wix.com’s platform aligns with local legal requirements.

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8. Communication with Site Users

8.1 Purposes of Communication

ANA may contact you for various purposes, including:

• Notifying you about your member account, member events and other services.

• Troubleshooting account-related issues.

• Resolving disputes.

• Collecting membership fees or outstanding payments.

• Soliciting your opinions through surveys or questionnaires.

• Providing regular updates about our organisation and your membership.

• Enforcing our website Terms of Use Policy, applicable national laws, and any contractual obligations we may have with you.

8.2 Methods of Communication

We may contact you via the following methods:

• Email.

• Telephone.

• Text messages.

• Postal mail.

• Other methods to which you have consented.

8.3 Compliance with Direct Marketing Regulations

We will:

• Obtain your explicit consent before sending marketing communications, unless an alternative lawful basis applies.

• Provide clear and simple methods for you to withdraw your consent or opt-out of marketing communications at any time.

• Ensure that service messages, such as those related to account administration or legal obligations, are distinguished from direct marketing communications.

 

9. Cookies Policy

9.1 Use of Cookies

We use cookies on our website to understand how you interact with it and to enhance your experience. By accepting, you consent to our use of such cookies. You can decline non-essential cookies and still access the website.

9.2 Third-Party Services

Our website may utilise third-party services, such as those offered through the Wix App Market, which may place cookies or employ other tracking technologies. These services have their own policies regarding the collection and storage of your personal data. As these are external services, their practices are not covered by the ANA or Wix Privacy Policy.

9.3 Managing Cookies

You can manage your cookie preferences through your browser settings, allowing you to:

• Delete all cookies.

• Block all cookies.

• Allow all cookies.

• Block third-party cookies.

• Clear all cookies when you close the browser.

• Open a private browsing session.

Please note that disabling certain cookies may affect the functionality of our website.

9.4 The following links explain how to access cookie settings in various browsers:

• Cookie settings in Firefox

• Cookie settings in Internet Explorer

• Cookie settings in Google Chrome

• Cookie settings in Safari (OS X)

• Cookie settings in Safari (iOS)

• Cookie settings in Android

9.5 To opt out of being tracked by Google Analytics across all websites, visit this link: http://tools.google.com/dlpage/gaoptout.

9.6 ANA's Cookie Policy

For more detailed information about our use of cookies, please view ANA Cookie Policy.

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10. Social Media Engagement

10.1 Interactions on Social Media Platforms

When you engage with ANA on our social media accounts, your interactions are subject to the terms and privacy policies of the respective platforms. We encourage you to review these policies to understand how your personal data is collected, used, stored and shared by these platforms.

10.2 Third-Party Data Practices

As these are external services, their data processing activities are not covered by the ANA Privacy Policy or WIX Privacy Policy. We recommend that you familiarise yourself with their privacy practices to make informed decisions about your data.

 

11. Email Marketing

11.1 Monitoring User Interactions

We monitor user interactions with our marketing emails, such as opens and clicks, to improve the relevance and effectiveness of our content. This practice aligns with our legitimate interests in understanding engagement and enhancing our communications.

11.2 Unsubscribing from Communications

Members can unsubscribe from our marketing communications at any time by notifying ANA (details are provided at the bottom of each email).

11.3 Data Sharing with Third Parties

We do not sell or rent your personal data to third parties. Data may be shared only with trusted third-party service providers where necessary for service delivery, with user consent, or as required by law. 

11.4 Compliance of Third-Party Service Providers

Any third-party service provider with access to personal data must comply with data protection standards equivalent to those required by law. 

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12. Right to Access and Erasure of Personal Data

12.1 Right to Access

You have the right to request access to your personal data held by us. This includes obtaining confirmation of whether we are processing your data, a copy of the data, and any other supplementary information. To make such a request, please contact us at datacontroller@appliedneuroscienceassociation.com.

12.2 Right to Erasure

You have the right to request the deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent. To request erasure, please contact us at datacontroller@appliedneuroscienceassociation.com.

12.3 Response Timeframe

We will respond to your requests regarding access or erasure within one month of receipt. In certain situations, if the request is complex or numerous, we may extend this period by up to two additional months. If an extension is necessary, we will inform you within the initial one-month period, providing an explanation for the delay.

12.4 Retention Period

We retain personal data for a period of seven years of inactivity, after which it will be securely erased, unless a longer retention period is required by law or for legitimate business purposes.

 

13. Changes to the Information

13.1 We regularly review and update our Privacy Policy to ensure it reflects our current practices and complies with applicable laws.

13.2 If we intend to use personal data for a new purpose not previously outlined in this policy, we will update the Privacy Policy accordingly.

13.3 Any significant changes will be communicated to users prior to initiating the new processing activities, ensuring transparency and providing an opportunity for users to review and, if necessary, update their preferences.

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