This privacy policy sets out how ICC Commercial Crime Services (CCS) uses and protects any information that you give CCS when you use this website.

CCS is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this statement.

1. Who is collecting and responsible for your data
Our privacy policy applies to the personal data that the CCS collects, processes, stores and uses.

The term "CCS" or "us" or "we" refers to the owner of the website whose registered office is Cinnabar Wharf, 26 Wapping High Street, London, UK, E1W 1NG. The term "you" refers to the user or viewer of our website.

CCS controls how your personal data is collected and the purposes for which we use your personal data. CCS is the “data controller” for the purposes of the GDPR Regulation (EU) 2016/679 of 27 April 2016.

2. Legal basis for us to collect your personal data
We base the collection and processing of your personal data in order to legitimately run our daily business and being able to provide you with our services.

3. What personal data we collect
The term “personal data” relates to you and allows us to identify you. This may include, but not be limited to; your name, job title, organisation name you work for, type of organisation you work for, contact details including address, telephone number and email address.

4. How we collect your personal data
In most cases your personal data will be provided to us by yourself, when you send us an email request or by completing the forms on our website for our services, piracy reports or courses and conferences. Your data, may also be collected through references or when sent to us by your organisation as a business requirement for us to provide you with our subscription services. 

5. Why we collect your personal data and how we will use it
We collect your personal data to aid in providing you with our professional services. These could include but not be limited to:

Our daily professional services to you
As a subscribing member of the CCS services, you are privileged to receive advise from the CCS family. This includes the International Maritime Bureau (IMB) on trade finance issues, the Financial Investigation Bureau (FIB) on financial crime and fraud, the Counterfeiting Intelligence Bureau (CIB) pertaining to the counterfeiting industry, the Piracy Reporting Centre (PRC) on alerts, incidents and reports pertaining to piracy and armed robbery at sea and FraudNet on legal insolvency asset recovery issues and access to FraudNet members. This information will be provided to you via the CCS secure portal or your email address.

Courses and conferences organised by the CCS
The CCS promotes information sharing and knowledge growth within its area of expertise. This is done by the organising of courses and conferences covering a range of topics related to commercial crime. 

To communicate with you and manage our relationship with you
We will also use your personal data to contact you after you have sent us an email request, filled in a web-form through our website to receive reports or contacted us on social media. Your opinion is important to us, so we may send you an email to seek your feedback. We may use the information to improve our products and services. We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. From time to time, we may also use your information to contact you by phone or email for market research purposes.

6. Sharing your personal data
In order to fulfil our business requirements, we will share your personal data, only within the CCS family. Your personal data will be held on hosted systems not owned by us. These systems are hosted within a third party’s premises within the EU. In addition, by the nature of the business we provide your personal data will be accessible to our software development subcontractors who act as data processors on our behalf. We have confidentiality agreements in place, which prohibit them from using distributing, selling your personal data for any purposes.
 
Courses and Conferences
If you are participating in our courses or conference, your personal data may be made available, on request and with your permission, to the speakers / other participants at the event. 

Credit and debit card companies. CCS will require to share some of your personal data, which includes information about your method of payment to the service provider used for processing the payment.

Authorities. We may disclose your personal data when this is required by the law of any jurisdiction to which we may be subject unless this is expressly prohibited by EU Member State law or the law of an EU country to which CCS is subject.

CCS will never knowingly sell, distribute or lease your personal information to third parties. We may use your personal information to send you promotional information about third parties in our own newsletters which we think you may find interesting.

7. Security of your personal data
The CCS is focused on ensuring that your personal data is secure. To demonstrate our commitment to we have gained the required ISO 27001:2013 Information Security Management Accreditation and have put in place suitable physical, electronic and managerial procedures to safeguard and secure your personal data and prevent unauthorised access or disclosure.
8. Your rights
You have certain legal rights under the EU data protection legislation, which you can enforce against CCS. A summary of these rights is provided below. For complete information regarding your rights, please see the General Data Protection Regulation (Regulation (EU) 2016/679), sections 3–5.

Right of access. You are entitled to be informed as to whether CCS is processing personal data about you. If we are, you are entitled to information regarding, among other things, which personal data we are processing, the purposes of the processing, which external recipients have access to your personal data, and how long we save your personal data.

Right to data portability. You have a right to receive a copy of the personal data which you have provided to CCS, in a structured, commonly used, and machine-readable format. You also have the right to require that we transfer this personal data to another controller of personal data. The right to data portability applies to personal data which is processed in an automated manner and which is based on your consent or on an agreement to which you are a party.

Correction of erroneous data. You have a right to require that CCS corrects erroneous or incomplete information about you.

Deletion of certain data. You have a right to require CCS to delete your personal data under certain circumstances, for example where the personal data is no longer necessary for the purpose for which we collected it.

Right to object to CCS’s processing of personal data. You have the right, under certain circumstances, to object to CCS processing of your personal data.

Right to object to direct marketing. You have the right at any time to object to CCS processing your personal data for direct marketing purposes. If you object to such processing, CCS must discontinue all direct marketing to you without undue delay.

Right to restrict the processing of your personal data. You have the right to require CCS to restrict its processing of your personal data in certain circumstances. For example, if you have denied that your personal data is correct, you can request a restriction on the processing during a period of time which allows CCS to verify whether the personal data is correct.

Right to withdraw consent. If our processing is based on your consent, you have the right to withdraw your consent to our processing of your personal data at any time. Such withdrawal does not affect the lawfulness of our processing based on your consent before its withdrawal.

Complaints. If you have any complaints regarding CCS processing of your personal data, you are entitled to file such complaints with the Data Protection Authorities.

If you have questions in relation to your personal data or would like to submit a request for an extract from the register, data portability, correction, deletion, objection, restriction or withdrawal of consent, please contact us at: ccs@icc-ccs.org

9. For how long we process your personal data
We will retain your personal data for as long as we need it in order to fulfil our services and business needs as set out in this Privacy Policy. We may also save your personal data for a longer period of time where necessary in order to fulfil a legal obligation which requires processing by law or in order for us to be able to establish, enforce, or defend against legal claims.

10. How we use cookies or other tracking technologies
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This could help us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.

Overall, cookies help us provide you with a better website experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

11. Transfers of personal data outside of the EU
Your personal data will be processed by our staff within the EU and by our staff in our branches in Dubai and Malaysia.

12. Updates to our Privacy Policy
CCS may change this policy from time to time by updating this page to reflect changes in the Data Protection Legislation. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 20th May 2018.

13. Contact information
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to ccs@icc-ccs.org