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1. Why this Privacy Policy?
Every user of this application (hereinafter "User") discloses a certain amount of personal data to various parties. As you are a natural person who can be uniquely identified based on this data, explicit consent must be given for the processing of this data, both for ESGO and for KLUBS, the software behind this application.
We process this data in accordance with the GDPR (Regulation (EU) 2016/679) regarding the protection of personal data.
By using this application, you consent to the processing of data as described in this privacy policy. ESGO always has the right to amend this privacy policy. Any substantial change will be communicated to the Users and will require a renewed explicit consent via the Membership Platform hosted via KLUBS.
2. Who is responsible for the processing of personal data?
2.1. Data Controller
ESGO acts as the controller of the personal data processing. If you wish to amend your data in KLUBS, you can always do so by contacting membership@esgo.org or via your own profile. ESGO has the necessary capabilities under GDPR legislation to delete, export, and modify your data from the platform if needed. You can contact ESGO in relation to your data and how it is managed via gdpr@esgo.org.
2.2. Data Processors
KLUBS acts as the data processor and cannot modify profiles itself without the explicit consent of ESGO. KLUBS acts as a technical party to maintain the software and consequently collects the necessary personal data on its servers to keep the platform running. KLUBS will also always request approval from ESGO for any direct access to certain data.
3. Legal basis for processing
We process your data based on explicit consent (opt-in after registration or account creation). When ESGO modifies or adds data to your profile, they do so solely on their own responsibility and assuming the User's consent. Users can withdraw consent at any time without affecting the lawfulness of prior processing. If, for example, an official membership with user terms exists between ESGO and the User, this can additionally be considered a legal basis for processing to enable society management. ESGO may rely on multiple legal bases (eg, consent, contract, legitimate interest) depending on the context.
4. What data is processed?
KLUBS will only process the necessary data to guarantee you access to the platform. These are the following fields: email address, name and surname, and password. All additional information in the profile can be supplemented by ESGO and by the User themselves. Since ESGO can create unlimited profile fields, this can include all kinds of information. However, ESGO commits to only requesting the necessary data that is relevant for the processing of the User's membership data (e.g., contact details, workplace details, date of birth, sex, nationality, profile picture, etc.).
5. For what purposes is my data processed?
KLUBS and ESGO collect your personal data solely for optimising member management, making member profiles transparent, and registering for activities or memberships. This processing is therefore considered essential to guarantee the optimal functioning of the society.
Your data is processed for the following purposes:
When using the application, user logs may be registered that indicate when and how the User has used the application. These are used only for statistical purposes and are in no way used to confront Users with their browsing behaviour.
6. Who processes your personal data as a sub-processor?
Your data is only processed for internal use. However, KLUBS may use sub-processors (a third party engaged by KLUBS to process personal data on its behalf) for the optimal functioning of the application. Care is taken to ensure that your data is not sent to unknown processors outside the EU. By approving this privacy policy, you also agree to the processing by the following sub-processors:
KLUBS takes the necessary legal and technical precautions to prevent unlawful use of the application. In the event of a data breach, KLUBS will do everything in its power to protect the data as quickly and effectively as possible and prevent further misuse. As a User, you will be informed of this immediately as required by law.
7. How long is your data stored?
User data is processed as long as it is deemed necessary for the operation of the society. When the User is no longer a member, they can choose to have the data deleted without delay and immediately. If not, the data is by default stored for marketing and accounting purposes. The User can opt out of marketing emails at any time. Data is kept for accounting purposes for 10 years in accordance with Act No. 563/1991 Coll., on Accounting, and Act No. 235/2004 Coll., on Value Added Tax.
8. What rights do I have as a User?
8.1. Legitimate processing and protection of data
User data is always processed lawfully and legitimately as described in section 5. It is processed in a secure and relevant environment and is not stored in the application for longer than necessary.
8.2. Right to access data
If desired, a User can request the right to access their data. Of course, this can be done via the profile, where the data can potentially be managed and copied by the User. In addition, the User also has the right to request an overview of all processed data from ESGO. The latter will consequently provide an overview of all processed data, including memberships and attendances at activities. ESGO commits to processing such requests within a reasonable period (1 week).
8.3. Right to correction of data
Incorrectly processed data can be adjusted in the application by both the User and ESGO.
8.4. Right to be forgotten
Every User always has the right to be forgotten in the application and database. Various rules apply here, whereby such a request must always be approved by ESGO. After all, the processing of data may be necessary to continue a membership. Under the following assumptions, a User can have their data deleted in the following circumstances:
In the case of data deletion, KLUBS reserves the right to reduce the names of the persons to initials and to limit the email addresses to the format a*****@g****.c** (meaning alexander@gmail.com) to be able to demonstrate statistics and proof of deletion. Statistical data is retained only in an anonymised form. All other personal data is deleted.
8.5. Right to data portability
Users have the right to obtain their personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller where technically feasible.
8.6. Right to object to processing
Users have the right to object at any time to the processing of their personal data carried out based on legitimate interest, including processing for direct marketing purposes. In such cases, ESGO will no longer process the data unless there are compelling legitimate grounds that override the interests, rights, and freedoms of the User, or where the processing is required for the establishment, exercise, or defence of legal claims.
8.7. Right to lodge a complaint
If a User believes that their personal data has been processed unlawfully or in breach of applicable data protection regulations, they have the right to complain to a supervisory authority.
Appendix A: Change Log
| Date | Version | Summary of Change |
|---|---|---|
| 24 Oct 2025 | 1.0 | Initial publication |