1. Introduction
WilGlobo Digital Equity Hub ("we," "our," or "us") is committed to protecting the personal data of our clients, employees, and other stakeholders. This Data Protection Policy outlines our practices concerning the collection, use, storage, and protection of personal data.
2. Scope
This policy applies to all personal data processed by WilGlobo Digital Equity Hub, regardless of the format in which the data is stored or the means by which it is collected.
3. Data Protection Principles
We adhere to the following principles when processing personal data:
- Lawfulness, fairness, and transparency: We process personal data lawfully, fairly, and in a transparent manner.
- Purpose limitation: We collect personal data for specified, explicit, and legitimate purposes and do not process it in a manner incompatible with those purposes.
- Data minimization: We ensure that personal data is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
- Accuracy: We take reasonable steps to ensure that personal data is accurate and, where necessary, kept up to date.
- Storage limitation: We keep personal data in a form that permits identification of data subjects for no longer than necessary for the purposes for which it is processed.
- Integrity and confidentiality: We process personal data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
- Accountability: We are responsible for and can demonstrate compliance with these principles.
4. Legal Basis for Processing
We process personal data only when we have a legal basis to do so, such as:
- The data subject has given consent
- Processing is necessary for the performance of a contract
- Processing is necessary for compliance with a legal obligation
- Processing is necessary to protect vital interests
- Processing is necessary for legitimate interests pursued by us or a third party
5. Data Subject Rights
We respect the rights of data subjects, including:
- The right to be informed about the collection and use of their personal data
- The right to access their personal data
- The right to rectification of inaccurate personal data
- The right to erasure (the 'right to be forgotten')
- The right to restrict processing
- The right to data portability
- The right to object to processing
- Rights related to automated decision-making and profiling
6. Data Security
We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:
- Encryption of personal data where appropriate
- Regular testing, assessing, and evaluating the effectiveness of security measures
- Restricting access to personal data to authorized personnel
- Implementing backup and recovery procedures
- Regular security awareness training for staff
7. Data Breach Procedures
In the event of a personal data breach, we will:
- Notify the relevant supervisory authority within 72 hours, where feasible, unless the breach is unlikely to result in a risk to the rights and freedoms of individuals
- Notify affected data subjects without undue delay when the breach is likely to result in a high risk to their rights and freedoms
- Document all breaches, including the facts, effects, and remedial action taken
8. Data Protection Impact Assessments
We will conduct Data Protection Impact Assessments (DPIAs) when processing is likely to result in a high risk to the rights and freedoms of individuals, particularly when using new technologies.
9. International Data Transfers
We will only transfer personal data outside the jurisdiction in which it was collected if appropriate safeguards are in place and the data subject's rights remain enforceable and effective legal remedies are available.
10. Data Protection Officer
We have appointed a Data Protection Officer (DPO) responsible for overseeing our data protection strategy and implementation to ensure compliance with data protection requirements.
11. Training
We provide regular data protection training to all staff who have access to personal data.
12. Review and Updates
This policy will be reviewed annually and updated as necessary to reflect best practice, changes in legislation, and organizational changes.
13. Contact Information
For questions about this Data Protection Policy or to exercise your rights as a data subject, please contact our Data Protection Officer at:
Email: dpo@wilglobo.com
Phone: +1 (123) 456-7890
Address: 123 Digital Avenue, Suite 456, Toronto, ON M5V 2K7, Canada
