Data Privacy Notice
1 Scope and purpose of this privacy policy
This privacy policy (hereinafter the “Privacy Policy”) informs you, as a user of the American Cathedral of the Holy Trinity in Paris’ website available at: www.amcathparis.com and www.americancathedral.org (hereinafter the “Website”), about the way the American Cathedral of the Holy Trinity (the “American Cathedral”) processes, as controller, information enabling us to identify you either directly or indirectly (hereinafter “Personal Data”) in the context of your use of the Website.
2 Categories of personal data processed and purposes of processing
When you use the Website, the American Cathedral processes your Personal Data for various purposes, each of them having a valid legal basis, as described below.
Purposes - Personal Data Collected - Legal Basis
Managing and following up any message you may send: Identification data (i.e. your first and last names and your email address), content of the message(s) you send to the American Cathedral of the Holy Trinity. Legal basis: Our legitimate interest, which consists of duly managing the American Cathedral’s relationship with you and providing efficient support and assistance.
Managing your pledges, donation, legacies, flower dedications and other financial gifts: Identification data (i.e., your first and last names, your email address, your mailing address and phone number) the first and last names of the person(s) you dedicate flowers to), financial information (amount of your contributions, credit card information, bank account details and tax receipts). Legal basis: Your consent.
Managing your volunteer activity: Identification data (i.e., your first and last names and your email address), professional position, professional and personal skills, interests and, occupation preferences. Legal basis: Our legitimate interest which consists of duly managing the volunteers and our voluntary actions.
Managing any potential or alleged disputes with you or third parties: Identification data (i.e., your first and last names and your email address), content of the message(s) you send to the American Cathedral of the Holy Trinity. Legal basis: Our legitimate interest to ensure the defence of our interests in court.
The American Cathedral of the Holy Trinity also uses cookies and other tracking devices on the Website to ensure it functions properly and to optimize the Website. For more information about cookies, please refer to the Cookies Policy
In any event, and disregarding the processing purpose at stake, please note the American Cathedral will comply with a strict data minimisation principle and will thus only collect and process Personal Data that is necessary for the above purposes.
Please note that, under certain circumstances, providing your Personal Data is mandatory, as otherwise the American Cathedral will not be able to provide you with the services you request (e.g., your email is mandatory in order for the American Cathedral to reply to your question or request).
3 Data recipients
To perform statistics on the number of visitors of the Website, the American Cathedral relies on the services of SquareSpace and Google Search Console, which accesses and processes your Personal Data resulting from the deposit of cookies.
In addition, the American Cathedral may also communicate your Personal Data to auditors or other advisers auditing, assisting with or advising the American Cathedral on any aspect of its activities, including notably its external consultants and legal advisors.
In any event, the American Cathedral communicates your Personal Data to the above recipients on a strict need-to-know basis and only as necessary for fulfilling duly identified processing purposes.
4 Transfers outside the European Union
When transfers outside the European Union are required for the processing of your Personal Data, the American Cathedral prefers transfer to countries that ensure an adequate level of protection in accordance with the requirements of the European Commission.
If it is not possible, transfers are subject to appropriate safeguards to ensure the security of Personal Data and to allow you to exercise your rights and have effective remedies. Thus, in the absence of an adequacy decision, the transfers are framed by the European Commission's standard contractual data protection clauses. You can obtain a copy of such standard contractual clauses by addressing a request to the address provided in Section 7 (Contact details) below.
5 Data retention periods
The American Cathedral only retains your Personal Data for a retention period not exceeding what is necessary for the purpose of the processing at stake.
As a result, the data retention period implemented by the American Cathedral depends upon the processing purposes as detailed above in paragraph 3.
First, with respect to the management of your messages, the American Cathedral will not retain your Personal Data for more than three (3) years following the later of the collection of the Personal Data or the last contact at your initiative.
Second, where the American Cathedral processes your Personal Data for managing your pledges, donations, legacies and flower dedications, your Personal Data will be retained by the American Cathedral for (5) years following the later of the collection of the Personal Data or the last contact on your initiative.
Third, where the American Cathedral processes your Personal Data for managing your volunteer activity, your Personal Data will be retained by the American Cathedral for (3) years following the collection of the Personal Data.
Finally, where the American Cathedral processes your Personal Data for managing any potential or alleged disputes with you or third parties, your Personal Data will be retained by the American Cathedral during the applicable legal prescription period.
Lastly, the Personal Data processed by the American Cathedral or on its behalf for performing audience measurement operations will not be retained for more than twelve (12) months. The cookies deposited to ensure that the Website functions properly will be retained for six (6) months. For more information about cookies used on the Website, please refer to the Cookies Policy
Where the applicable retention period expires, the American Cathedral either deletes your Personal Data or irrevocably anonymises them so that you can no longer be identified.
When the American Cathedral considers it does not need to retain your Personal Data in its active database, it will archive it and will ensure that access thereto is restricted to a limited number of persons having an actual need to access your Personal Data.
6 Your rights and obligations as data subject
As a data subject of the processing we carry out, you benefit from various rights regarding the processing of your Personal Data. These are as follows:
right to request from the American Cathedral access to your Personal Data: this right enables you to receive a copy of the Personal Data that the American Cathedral holds about you and to check that the American Cathedral is lawfully processing it.
right to request from the American Cathedral the rectification of your Personal Data: this right enables you to have any incomplete or inaccurate information that the American Cathedral holds about you corrected.
right to request from the American Cathedral the erasure of your Personal Data: this right enables you to ask the American Cathedral to delete or remove Personal Data where there is no good reason for continuing to process it. You also have the right to ask the American Cathedral to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
right to request from the American Cathedral restriction of the processing of your Personal Data: this right enables you to ask the American Cathedral to suspend the processing of Personal Data about you, for example if you want the American Cathedral to establish its accuracy or the reason for processing it.
right to object to the processing of your Personal Data: you may use this right where the American Cathedral relies on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground, or where your Personal Data is processed for direct marketing purposes.
right to portability of your Personal Data: this right enables you to ask for a transfer of your personal data, in a reusable format, to you or to a third party elected by you.
right to specify guidelines regarding the use of your Personal Data after your death: this right enables you to inform the American Cathedral of the fate you want your Personal Data to have after your death, whether by specifying rules on the retention of such personal Data, its deletion, its transmission to a third party, or by appointing a third party to grant him/her access to your Personal Data after your death.
right to withdraw the consent you gave, at any time and without affecting the lawfulness of processing based on your consent before withdrawal thereof: you may use this right to withdraw the consent you gave to the American Cathedral to send you its newsletter if you do not wish to receive it anymore; and
right to lodge a complaint with the French Data Protection Authority, the CNIL: you may use this right if you have a complaint about the way in which the American Cathedral is managing and processing your Personal Data.
Nevertheless, it is important to note that some of the abovementioned rights can only be exercised under the conditions and within the limits provided for by the applicable legal framework (i.e., the General Data Protection Regulation No. 2016/679 dated April 27, 2016 (GDPR) and, in France, the French law No. 78-17 of January 6, 1978, as amended). In this respect, if your particular case does not meet the legal requirements to do so, we may inform you that we cannot let you exercise the concerned right, and we will explain you the reasons justifying our refusal.
Please note that the American Cathedral remains at your disposal should you decide to exercise your right(s) and/or to answer any of the questions you may have on your rights and their limitations, by contacting it to the address specified on Section 7 (Contact details) below.
The American Cathedral is committed to utmost care when it comes to protecting your Personal Data and complying with the applicable data protection legal framework.
This is the reason why the American Cathedral requires your assistance to this end. Thus, you commit to inform the American Cathedral if the Personal Data you shared with the American Cathedral becomes obsolete or inaccurate.
In addition, in the event you provide the American Cathedral with information enabling usto identify directly or indirectly any other natural persons (e.g. you sent a request to the American Cathedral with the contact email address available on the Website and share personal data concerning another natural personal in your email), you represent and warrant that, prior to sharing this information with the American Cathedral, such other natural persons have been provided with this Privacy Policy and, to the extent applicable, have consented to the processing of their data.
7 Contact details
Should you have any questions or requests regarding the processing of your Personal Data by the American Cathedral, including the exercise of your rights specified in Section 6 (Your rights and obligations as data subject) above, please feel free to contact the American Cathedral by using the following contact details:
Timothy Thompson
Parish Coordinator
23 avenue George V, 75008 Paris FRANCE
parish.coordinator@americancathedral.org
When contacting the American Cathedral, please: (i) provide your name and address; (ii) expressly specify your request, question, or complaint; and (iii) where applicable, provide brief details of the Personal Data concerned. This will help the American Cathedral process your request more efficiently.