Privacy Policy

Last Modified: 04.01.19

The International Association for the Study of Lung Cancer (“IASLC”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy is divided up into the following sections:

  1. Introduction
  2. Children under the age of 13
  3. Data IASLC collects about you
  4. How IASLC collects your personal data
  5. How IASLC uses your personal data
  6. How IASLC discloses your personal data
  7. Choices about how IASLC uses and discloses your personal data
  8. Accessing and correcting your personal data
  9. Data security
  10. Retention
  11. Changes to our Privacy Policy
  12. Contact information
  13. Personal data subject to GDPR
  14. Lawful basis for processing your personal data
  15. More information about how IASLC discloses your personal data
  16. International transfers
  17. Your rights under GDPR
  18. Complaints
  19. Introduction

This Privacy Policy relates to your use of our websites iaslc.org and lcam.org (collectively, the “Sites”), which are operated by IASLC. It contains important information regarding IASLC’s practices for collecting, using, maintaining, protecting, and disclosing your personal data, and your rights in relation to such personal data.

This Privacy Policy applies to information IASLC collects on our Sites. It does not apply to information collected by IASLC offline or through any other means. It also does not apply to any information collected by any third party including through any application or content (including advertising) that may link to or be accessible from or on a Site. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Please note that, for users located in the European Economic Area (“EEA”), section 13 provides additional information regarding how IASLC processes your personal data and supplements sections 1 through 12. In the event of any inconsistency between the statements made in sections 1 through 12 and section 13, the terms in section 13 will take precedent.

  1. Children under the age of 13

The Sites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on a Site. IASLC does not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on our Sites or on or through any of their features, or register on the Sites, make any purchases through the Sites, use any of the interactive or public comment features of the Sites or provide any information about yourself, including your name, address, telephone number, email address, or any screen name or user name you may use. If IASLC learns it has collected or received personal data from a child under 13 without verification of parental consent, IASLC will delete that information. If you believe IASLC might have any information from or about a child under 13, please contact IASLC at lcam@iaslc.org.

  1. Data IASLC collects about you

IASLC collects several types of information from and about users of our Sites, which varies depending on the particular activities carried out through a Site. Such information may include information by which you may be personally identified (“personal data”), such as:

  • Identity data, including your name, username or similar identifier (“Identity Data”);
  • Contact data, including your postal address, social media handle, email address and telephone numbers (“Contact Data”);
  • Transaction data, including details about donations or purchases of IASLC or Lung Cancer Awareness Month (“LCAM”) merchandise (“Transaction Data”);
  • Technical data, including internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Sites (“Technical Data”);
  • Profile data, including information about your communication preferences, feedback and survey responses, any information you may give IASLC when making an inquiry on our Sites and feedback forms or by email/telephone (“Profile Data”);
  • Usage data, including information about how you use our Sites or services (“Usage Data”); and
  • Marketing and communications data, including your preferences in receiving information about our promotional campaigns or educational presentations or courses, fundraising efforts, news, updates, events and other activities of relevance to IASLC, LCAM and the awareness of lung cancer (“Marketing and Communications Data”).

IASLC also collects, uses and shares aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data, but it is not considered personal data since it will not directly or indirectly reveal your identity. For example, IASLC may aggregate Usage Data to calculate the percentage of users accessing a specific feature of a Site.

IASLC does not collect any information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic or biometric data, nor does it collect any information about criminal convictions and offenses. However, when a user submits and shares a lung cancer survivor story to IASLC (a “Story”), the Story may contain certain sensitive information, such as information related to an individual’s health. IASLC obtains users’ explicit consent to submit Stories on the Sites and will obtain users’ explicit consent in the event it collects any other such sensitive information.

Please note that, where IASLC needs to collect personal data by law, or under the terms of a contract it has with you, and you fail to provide that data when requested, IASLC may not be able to perform the contract it has or is trying to enter into with you.

  1. How IASLC collects your personal data

IASLC uses different methods to collect data from and about you, including through:

  • Direct interactions. You may give IASLC or our service providers your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with IASLC or our service providers by post, phone, email or otherwise. This includes personal data you provide when you: (i) make a donation or purchase IASLC or LCAM merchandise; (ii) register on a Site; (iii) request information about IASLC’s charitable activities, fundraising efforts or other activities of relevance to IASLC, LCAM, and the awareness of lung cancer; (iv) request resources, information, publications or materials related to IASLC or LCAM campaigns, educational presentations or courses, events, fundraisers or similar activities; (v) subscribe to receive updates from IASLC about our charitable and fundraising activities; (vi) complete a survey; (vii) submit a Story; or (viii) provide feedback about an event, publication, the Sites or other activities or services provided by IASLC.
  • Automated technologies or interactions. As you interact with our Sites, IASLC will automatically collect Technical Data about your equipment, browsing actions and patterns. IASLC collects this data, which may be considered personal data in applicable jurisdictions, by using cookies and other similar technologies. Cookies are small text files which are placed onto your device when you use or access a website. We may use cookies and other similar tracking technologies on our Sites, which help us recognize you and your device and store some information about your preferences or past actions. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly. For more information about the cookies we use, please visit our Cookie Policy
  • Third parties or publicly available sources. IASLC may receive personal data about you from various third parties and public sources, including: (i) Technical Data from analytics providers and/or advertising networks, which may be based in the United States; (ii) Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services; and (iii) Identity Data and Contact Data from publicly available sources.
  1. How IASLC uses your personal data

IASLC uses personal data to:

  • Register you on a Site;
  • Manage our relationship with you, which includes notifying you about changes to our Terms of Use or this Privacy Policy, thanking you for your support, donation or sponsorship, asking you to provide feedback or take part in a survey, or contacting you to let you know if IASLC has taken any action following your feedback;
  • Administer and protect IASLC and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • Publish and share user Stories on our Sites, social media pages, in educational and informational presentations and courses, and in digital and print promotional and advertisement materials to promote IASLC and LCAM publications;
  • Use data analytics to improve our Sites, products, services and marketing, and user, supporter and beneficiary relationships and experiences;
  • Make suggestions and recommendations to you about goods or services that may be of interest to you, and keep you informed about IASLC and LCAM promotional campaigns or educational presentations or courses, fundraising efforts, news, updates, events and other activities of relevance to IASLC, LCAM, and the awareness of lung cancer;
  • Process and deliver your orders or donations, including to manage payments, fees and charges, and collect and recover money owed to us;
  • Deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you; and
  • Provide you with the services, merchandise or information you have requested.

We may also use your personal data to contact you about IASLC and third-party (including other lung cancer patient advocacy organizations that we partner with for public awareness campaigns, such as the LCAM Coalition) merchandise and services that may be of interest to you. If you do not want us to use your information in this way, please follow the opt-out or unsubscribe links on any marketing message sent to you, or contact us at lcam@iaslc.org. For users located in the EEA, please see section 13(B) and (D) below for more information about your rights with regard to marketing communications.

If we make material changes to how we treat our users’ personal data, we will notify you by email or through a notice on a Site’s home page. For users located in the EEA, please see section 13(A) below for more information about the ways IASLC plans to use your personal data, which of the lawful bases IASLC relies on to do so, and how IASLC will notify you in the event it makes changes to how it treats your personal data.

  1. How IASLC discloses your personal data

IASLC may disclose information that does not identify any individual, including Aggregated Data, without restriction.

IASLC may disclose personal data that it collects or you provide as described in this Privacy Policy to: 

  • IASLC’s subsidiaries and affiliates;
  • Other non-profit lung cancer advocacy organizations and individuals as part of public awareness campaigns, including but not limited to, organizations and individuals that participate in the LCAM Coalition;
  • Contractors, service providers, and other third parties we use to support IASLC;
  • A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of IASLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by IASLC about users is among the assets transferred. IASLC may seek to acquire other organizations or merge with them. If a change happens to our organization, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

For more information about how IASLC discloses personal data of individuals located in the EEA, please see section 13(B) below.

  1. Choices about how IASLC uses and discloses your personal data

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information. For more information about how we provide choices about how IASLC uses and discloses personal data of users in the EEA, please see section 13(B) below.

  • You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Sites may then be inaccessible or not function properly.
  • You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you or by contacting us at any time at lcam@iaslc.org. Where you opt out of receiving these marketing messages, this may not apply to personal data provided to us as a result of a merchandise or service purchase, merchandise or service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising; however, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Please note that our Sites do not respond to browser Do Not Track signals at this time.

  1. Accessing and correcting your personal data

You may send IASLC an email at lcam@iaslc.org to request access to, correct or delete any personal data that you have provided to IASLC. IASLC may not be able to delete your personal data except by also deleting your user account or Story submission. IASLC may not accommodate a request to change information if it believes the change would violate any law or legal requirement or cause the information to be incorrect.

Please note that if you delete, or if you request that IASLC delete, your personal data and/or Story submission from the Sites, copies of your personal data and/or Story submission may remain viewable in cached and archived pages, or might have been copied or stored by other Site users.

  1. Data security

IASLC has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, IASLC limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on IASLC’s instructions and they are subject to a duty of confidentiality. IASLC has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where IASLC is legally required to do so.

  1. Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorized 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, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Changes to our Privacy Policy

It is IASLC’s policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal data, we will notify you either by email to the email address specified in your account and/or a notice on a Site’s home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Sites and this Privacy Policy to check for any changes.

Please see section 13(A) below for more information about how IASLC notifies users located in the EEA with regard to changes made to this Privacy Policy.

  1. Contact information

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at lcam@iaslc.org.

  1. Personal data subject to GDPR

The following terms apply to the extent IASLC processes personal data of data subjects in the EEA or data that is otherwise subject to the EU General Data Protection Regulation (2016/679) (“GDPR”) and laws and regulations implementing or supplementing the GDPR. The following terms explain how IASLC collects and processes data subjects’ personal data as a data controller if personal data is provided or disclosed by a data subject or if data subjects’ personal data is received or acquired through a third party. IASLC processes such personal data in accordance with the GDPR and laws and regulations implementing or supplementing the GDPR, to the extent applicable.

Processing of personal data under this section 13 means processing of personal data of persons who are in the EEA in any of the following cases: (i) if related to the offering of goods or services to such data subjects, or (ii) if related to the monitoring of a data subject’s behavior as far as their behavior takes place within the EEA.

  1. Lawful basis for processing your personal data

When IASLC uses your personal data, it relies on various different lawful bases depending on what personal data it processes and why. The lawful bases IASLC may rely on include:

  • Where you have given IASLC clear consent to process your personal data for a specific purpose (consent);
  • Where IASLC’s use of your personal data is necessary for a contract it has with you, or because you have asked IASLC to take specific steps before entering into a contract (contract);
  • Where IASLC’s use of your personal data is necessary for us to comply with the law (not including contractual obligations) (legal obligation); and/or
  • Where IASLC’s use of your personal data is necessary for IASLC’s legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides IASLC’s legitimate interests) (legitimate interests).

Please see below a description of all the ways IASLC plans to use your personal data, and which of the lawful bases it relies on to do so. Note that IASLC may process your personal data for more than one lawful ground depending on the specific purpose for which it is using your data. Please contact IASLC if you need details about the specific legal ground IASLC relies on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/activity

Type(s) of data

Lawful basis for processing

Register you on a Site

·         Identity Data

·         Contact Data

Performance of a contract with you

Provide you with the services, merchandise or information you have requested

·         Identity Data

·         Contact Data

·         Profile Data

·         Marketing and Communications Data

·         Usage Data

Performance of a contract with you

Necessary for our legitimate interests (to maintain a record of types of services, publications, questions and resources our users, supporters, fundraisers and beneficiaries require, so that we can keep our services, publications, Sites and other services relevant and improve our delivery of charitable activities and objectives)

 

Manage our relationship with you, which includes notifying you about changes to IASLC Terms of Use or this Privacy Policy, thanking you for your support, donation or sponsorship, asking you to provide feedback or take part in a survey, or contacting you to let you know if IASLC has taken any action following your feedback

·         Identity Data

·         Contact Data

·         Profile Data

·         Marketing and Communications Data

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated, to better understand how users, supporters and beneficiaries use, value and respond to our information and advice so that we can improve content, publications, and deliver our charitable objectives)

Administer and protect IASLC and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

·         Identity Data

·         Contact Data

·         Profile Data

·         Marketing and Communications Data

·         Usage Data

·         Technical Data

Necessary for IASLC’s legitimate interests (for running the organization, provision of administration and IT services, network security, to prevent fraud and in the context of a reorganization or group restructuring exercise)

Necessary to comply with a legal obligation

Deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

·         Identity Data

·         Contact Data

·         Profile Data

·         Usage Data

·         Marketing and Communications Data

·         Technical Data

Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our organization and to inform our marketing strategy)

Consent (in some cases)

Use data analytics to improve our Sites, products, services, marketing and user, supporter and beneficiary relationships and experiences

·         Usage Data

·         Technical Data

Necessary for IASLC’s legitimate interests (to define types of individuals for IASLC’s services, to keep the Sites updated and relevant, to grow our organization and to inform our marketing strategy)

Consent (in some cases)

Make suggestions and recommendations to you about goods or services that may be of interest to you, and keep you informed about IASLC promotional campaigns or educational presentations or courses, fundraising efforts, news, updates, events and other activities of relevance to IASLC and the awareness of lung cancer

·         Identity Data

·         Contact Data

·         Profile Data

·         Marketing and Communications Data

·         Usage Data

·         Technical Data

 

Necessary for IASLC’s legitimate interests (to develop our services and grow our organization)

Consent (in some cases)

Process and deliver your orders or donations, including to manage payments, fees and charges, and collect and recover money owed to us

·         Identity Data

·         Contact Data

·         Financial Data

·         Transaction Data

·         Marketing and Communications Data

Performance of a contract with you

Necessary for our legitimate interests (to help us fund our organization and to recover debts due to us)

Publish and share user Stories on the Site, with other non-profit lung cancer advocacy organizations and individuals as part of public awareness campaigns (including LCAM), on IASLC’s social media pages, in educational and informational presentations and courses, and in digital and print promotional and advertisement materials to promote IASLC publications

·         Identity Data

·         Contact Data

Consent

Please note that you may receive marketing communications from IASLC if you have requested information from us or purchased merchandise or services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you or by contacting us at any time at lcam@iaslc.org. Where you opt out of receiving these marketing messages, this may not apply to personal data provided to us as a result of a merchandise or service purchase, merchandise or service experience, or other transactions.

As mentioned in section 4 above, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly. For more information about the cookies we use, please visit our Cookies Policy.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at lcam@iaslc.org.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where required or permitted by law.

  1. More information about how IASLC discloses your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above:

  • Our subsidiaries and affiliates, some of which may be in the United States;
  • Service providers and other third parties, some of which may be in the United States, that we use to support IASLC;
  • Other non-profit lung cancer advocacy organizations and individuals as part of public awareness campaigns, including but not limited to, organizations and individuals that participate in the LCAM Coalition; and
  • A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of IASLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by IASLC about users is among the assets transferred. IASLC may seek to acquire other organizations or merge with them. If a change happens to our organization, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all subsidiaries, affiliates and third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside the data subject’s country of residence – to disclose personal data. We may also disclose personal data if we determine that, for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our internal regulations, investigate fraud, or protect our operations or users.

  1. International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (Standard Contractual Clauses).
  • Where we use providers based in the United States, we may also transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Your rights under GDPR

Under certain circumstances, you may have certain rights under EU data protection laws in relation to your personal data, including to:

  • Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) If you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month; however, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Complaints

IASLC hopes that it can resolve any query or concern you raise about IASLC’s use of your information. The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) state where you normally live or where any alleged infringement of data protection laws occurred.