Privacy Policy
ACES Europe processes and holds only a small amount of personal data on the EU population. This Statement of Privacy applies to the ACES Web site and governs data collection and usage. By using the ACES website, you consent to the data practices described in this statement.

What is personal data
Personal Data (or Data) is any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Owner and Data Controller
ACES Europe
Rond Point Robert Schuman 6 (Box 5)
1040 Bruxelles (Belgium)

Requesting your personal data
Where we ask for your personal information we will:
– let you know why we need it;
– only ask for what we need, and not collect excessive or irrelevant information;
– ensure that it is kept safe and secure and only accessible by those who need it;
– let you know if we will share it with other organisations to give you better services, how we will do that and whether you can say no;
– only keep it for as long as we need to;
– make sure it is accurate and kept up to date;
– not make it available for commercial use
To help us to keep your information reliable and up to date, we would ask that you:
– Give us accurate information;
– Tell us as soon as possible of any changes, such as a new address
We may share personal information within our organisation or with others where it would not be inconsistent with the purposes for which we collected it, and/or where we are required or permitted to do so by law.

What data will ACES Europe hold?
Among the types of Personal Data that the ACES website or ACES collects, there are: e-mail address, name, home or work address, telephone number. ACES also collect anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites. There is also information about your computer hardware and software that is automatically collected by ACES. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Web site.
Unless specified otherwise, all Data requested by this Web site is mandatory and failure to provide this Data may make it impossible for this Web site to provide its services. In cases where this Web site specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact Aces.
Any use of Cookies – or of other tracking tools – by this Web site or by Aces of third-party services used by this Web site serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Web site and confirm that they have the third party’s consent to provide the Data to Aces.

The training and guidance we give to our staff
All of our staff are trained in the importance of protecting personal and other sensitive information. Those who routinely access personal data as part of their jobs are expected to undertake more in depth training.
Managers who have formal responsibilities for large datasets, for example as information asset owners, will also receive additional training so that they have a clear understanding of what they need to do to keep the data under their control safe and secure.
As well as the above, all our staff are required to work in line with the core values of integrity, honesty, objectivity and impartiality. These values also apply to the handling of personal data.

Methods of processing
ACES Eruope secures your personal information from unauthorized access, use or disclosure. ACES secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Aces, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Web site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Aces. The updated list of these parties may be requested from Aces at any time.

​Legal basis of processing
Aces Europe processes Personal Data relating to Users if one of the following applies:
– Users have given their consent for one or more specific purposes. Note: Under some legislations Aces may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
– Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
– Processing is necessary for compliance with a legal obligation to which Aces is subject;
– Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Aces;
– Processing is necessary for the purposes of the legitimate interests pursued by Aces or by a third party.
In any case, Aces will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The Data is processed at Aces operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Aces to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Aces using the information provided in the contact section.

How long do you keep my personal information?
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
– Personal Data collected for purposes related to the performance of a contract between Aces and the User shall be retained until such contract has been fully performed.
– Personal Data collected for the purposes of Aces legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Aces within the relevant sections of this document or by contacting Aces.
Aces may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Aces may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow Aces to provide its Services, as well as for the following purposes: send you candidatures, congress or other meetings and events.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services: contacting the User.
Personal Data collected: company name, country, email address, first name and last name.

Do you share information with third parties?
This type of service allows interaction with social networks or other external platforms directly from this Web site.
The interaction and information obtained through this Web site are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data collected: Cookies and Usage Data.

The rights of Users
Users may exercise certain rights regarding their Data processed by Aces. In particular, Users have the right to do the following:
– Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
– Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
– Access their Data. Users have the right to learn if Data is being processed by Aces, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
– Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
– Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, Aces will not process their Data for any purpose other than storing it.
– Have their Personal Data deleted or otherwise removed. Aces have the right, under certain circumstances, to obtain the erasure of their Data from Aces.
– Receive their Data and have it transferred to another controller. Aces have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
– Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Aces or for the purposes of the legitimate interests pursued by Aces, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether Aces is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to Aces through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Aces as early as possible and always within one month.

Legal action
The User’s Personal Data may be used for legal purposes by Aces in Court or in the stages leading to possible legal action arising from improper use of this Web site or the related Services.
The User declares to be aware that Aces may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Web site may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this web site and any third-party services may collect files that record interaction with this Web site (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from Aces at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
ACES Europe reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Web site and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to Aces. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, Aces shall collect new consent from the User, where required.

​Latest update: May 15, 2018