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Privacy Policy UK ReThink '21 Online

Updated June 2021

Online event platform

Proactis ReThink ’21 Online, our annual spend management event, will be run online for 2021 using the Swapcard event platform and Avolio registration platform.

Registration for the event

In order to access the event, delegates must register by completing the form hosted via Avolio on the dedicated Proactis ReThink ’21 Online page of our website: which will ask for the delegates:

  • First name
  • Last name
  • Job title
  • Company
  • Email address
  • Phone number
  • Country

Cookies and the Swapcard / Avolio platforms

In common with standard industry practice, Swapcard uses cookies to operate the platform and to track site usage. They use cookies that are strictly necessary to enable/allow you to move around the event platform. They also use cookies to improve your experience by remembering your details so that you do not need to keep re-entering them when moving between registration and auditorium/event sites.

Their cookie policy can be viewed here: Proactis invites you to read this.

By registering for Proactis ReThink ’21 Online you are consenting to the use of cookies on both the event platform and the registration platform.

Personal Data Used

Your personal data is collected and processed for one or more of the following purposes:

  1. To manage your access to and use of the services available on the Platform.
  2. To carry out customer management operations relating to contracts, follow-ups with customers, or to arrange a meeting.
  3. To issue newsletters and other event invitations to you. Should you not wish to receive these, please update your personal preferences using the link in the email you will receive upon registering.
  4. To send you suggestions for networking connections with other users of the Platform. Should you not wish to receive these, we offer you the option to refuse them at the moment your data is being collected.
  5. To compile commercial and web traffic statistics for Swapcard’s services. The statistics used are anonymised and individuals cannot be identified from this information.
  6. To adhere to our legal and regulatory obligations.

We shall inform you, when requesting your personal data, if certain information must be provided or if it is optional. We shall also inform you of the consequences should you not wish to provide this information.

Your personal information is kept private and stored securely by Proactis, under the conditions and requirements as detailed in the GDPR and UK Data Protection Bill (2018) or other EU country versions of the GDPR, collectively known as “Data Protection Legislation” throughout this Policy. Proactis also ensures it is conforming to the requirements under the Privacy and Electronic Communications Regulation 2003 (‘PECR’).

Every effort has been made to ensure that a safe and secure email submission process exists, however we do advise those people who use such email forms that they do so at their own risk.

Data retention on the Swapcard event platform

The Proactis ReThink ’21 Online event runs over 3 days, from Tuesday 09 November 2021 to Thursday 11 November 2021, although the platform will be available for visitors for three months after this. The event will be formally closed on Monday 10 January 2022. Your personal data will be stored securely during this period. All personal data will be securely deleted from the event platform no later than 30th April 2022 after this final close date.

As Swapcard is an event platform, should you register for the Proactis ReThink ’21 event, this means you can continue to use Swapcard once the Proactis event has concluded. As such, you may feel it is beneficial to retain your access for future events. However, should you wish to have your personal data deleted prior to the advised timescale, please contact us via[email protected] and we will promptly do so.

Data sharing with event exhibitors

Your personal data will be shared with our event exhibitors if you visit their exhibitor booths on the Swapcard platform.

Our justification for processing this is by legitimate interest and we have conducted a Legitimate Interest Assessment as required under the GDPR and PECR, to ensure what we are doing is balanced and fair for both the event attendees and the event exhibitors.

If you visit our event exhibitors, you can opt out of having your personal data being shared with them. Please contact [email protected] to request this at least 24 hours before the event is due to commence.

Data sharing with our event platform provider Swapcard and registration platform provider Avolio.

To enable the Swapcard Application Services, a specific database is assigned to each Event. This contains all the personal data of Attendees or Exhibitors that has been uploaded by Proactis to the Application, as well as all personal data that Attendees or Exhibitors have provided directly to Swapcard via the registration Application, Avolio.

Swapcard, Avolio and Proactis undertake, each acting in their own sphere, to comply with the aforementioned Data Protection Legislation.

The service provided by Swapcard will require the processing of personal data on Proactis’ behalf in order to perform its obligations as an event platform provider. By registering for Proactis ReThink ’21 Online all delegates are accepting the following:

  1. Swapcard acts initially as an external data processor and then, post-event, as a data controller with regard to the personal data of those participating in Proactis ReThink ’21 Online.
  2. Your data is stored solely on the servers of Amazon, which are located in the Republic of Ireland. Your data will not be transferred outside the European Union, which is part of our conditions of using the services Swapcard offer.
  3. Your personal data shall not be retained any longer than is strictly necessary for the management of our business with you.
  4. Your personal data is kept for a period of 3 (three) years from the date of your last use of the Swapcard application. Please refer to the Data Retention section above for more information.
  5. Information enabling recognition of your right to opt-out is retained for a minimum of three (3) years by Swapcard following the exercising of your right to opt out.
  6. Information stored in users' terminals, or any other means used to identify users and enabling them to be tracked or to measure the frequency of their visits, shall be retained for no longer than thirteen (13) months.
  7. Information enabling the management of your requests to exercise your rights under the GDPR will be kept for 3 (three) years from the date of your request.
  8. We take all necessary precautions and appropriate organisational and technical measures to maintain the security, integrity and confidentiality of your personal data, and especially to prevent it from being altered or damaged and to prevent any third party from accessing it.
  9. In this regard, we respect the security measures put in place by Swapcard’s data hosting provider, Amazon, whose security measures can be accessed on their privacy policy page.

Swapcard: Collecting and processing personal data

We also inform you that Swapcard can collect your personal data indirectly, either from organisers of events which you are attending, or from other users of their services. This is to enable the ‘event participant’ networking functionality. This functionality allows for LinkedIn-style connections to be made between participants, to further increase engagement between event participants.

Note that this functionality is only operable within the Swapcard platform and does not interface with external applications. This functionality will only operate if users have agreed to have their data visible. Opting out can be conducted at point of registration or in the user’s Settings preferences on the Swapcard platform.

In this respect, you are hereby informed that Swapcard may reuse your personal data that is stored in the Swapcard address book of another user of the Swapcard platform who has expressly authorised us to access their contact information to put you in contact with each other.

Assignment of your personal data

Your personal data will not be assigned to, rented to or exchanged with any third party, with the exception of Swapcard and Avolio through which you are registered for Proactis ReThink ’21 Online and to whom we provide data concerning you, in relation with our event.

We may generate, and share with Exhibitors at the event for which you are registered, usage statistics collected by Proactis during Proactis ReThink ’21 Online, in order to calculate the rate of use of the Swapcard platform and have a clear understanding of interactions during the event. This data includes both anonymous generic usage data (e.g. number of users, average number of user contacts, percentage of user additions, number of active users) and personal data related to events organised Proactis and for which you are registered.

Legal basis for processing your data

Swapcard process your data on the basis of the following legal grounds:

  1. Performance of the contract you have entered into with us to use our services on the Swapcard Platform.
  2. Swapcard’s legitimate interest in developing and promoting their business.
  3. Swapcard’s legitimate interest in training their employees.
  4. To comply with the legal and regulatory obligations to which Swapcard may be subject.

Access to and rectification, restriction or erasure of your personal data

You have the right to obtain and, where appropriate, rectify or delete any data concerning you, via online access to your account. You can also get in touch with Proactis to request any of the above, by emailing [email protected].

You can also request the restriction of processing of personal data concerning you in certain cases as defined in Article 18 of the GDPR, using the same email address.

These rights can be exercised free of charge, at any time, and in particular when closing your account on the Swapcard platform, in order to recover and keep your personal data.

In this context, Swapcard will send you your personal data, through appropriate channels, in a commonly-used and machine-readable standard open format.