PRIVACY POLICY

Updated: October 2021

SCOPE
1. This Privacy Policy applies to the processing of your personal data as part of your visit to this Narconon Centre identified below and the Narconon International websites (“Websites”), your communication with us via e-mail, telephone, fax and our social media channels (such as Facebook, Twitter, and Instagram), your request for more information, and your registration for or participation in the Narconon program.
2. If you want more information on how we process personal data via cookies, social plugins and other types of tracking technology, you are kindly referred to our Cookie Policy https://www.narconon.eu/cookie-policy/
3. Where reference is made in this Privacy Policy to laws or regulations, any amendments to these laws or regulations are implicitly included.
4. We reserve the right to change and adapt this Privacy Policy on our own initiative. In that case, those changes and adaptations will be communicated to you via our Websites at least two weeks before those changes and adaptations will become applicable. Any further use of our Websites will be subject to the amended Privacy Policy.
WHO ARE WE?
1. Narconon Europe is located outside of Helsinge in Denmark and provides drug rehabilitation services. Narconon Europe helps those enslaved by drugs and alcohol to build new lives filled with purpose and productivity and also provides training to professionals and organizations seeking workable drug rehabilitation and prevention solutions. The Narconon program is an evidence-based, drug-free approach to rehabilitation.
2. Narconon International licenses individual Narconon Centres to deliver the Narconon program.
3. Narconon International is one of the social betterment initiatives of the Association for Better Living and Education International (“ABLE”, “we”, “us,” “our”), 7065 Hollywood Boulevard, Los Angeles, CA 90028, United States of America. ABLE is committed to protecting the privacy and security of your personal data at all times and can be reached via e-mail at dpo@able.org.
4. ABLE coordinates the data processing of Narconon Centres worldwide, including those in the European Union.
WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
1. ABLE acts as data controller for the personal data that you provide to Narconon International or to Narconon Europe via our website or call centre in the context of the enrolment into and delivery of the Narconon programme.
2. Narconon Europe and Narconon International act as data processors on behalf of ABLE. While ABLE, as data controller, determines the purposes and means of the data processing, this does not mean that all of your personal data will be transferred to ABLE. On the contrary, your personal data will be processed by Narconon Europe for the purpose of ensuring proper delivery of the Narconon rehabilitation programme and to follow up the results of the programme after your graduation.
3. For each Narconon treatment centre, there is a separate website and associated data, and your personal data will not be transferred to, or shared with, any other Narconon treatment centre without your express written permission. We may share your personal data with Narconon International and with ABLE for the limited purposes that are explained in this policy.
WHICH OF YOUR PERSONAL DATA DO WE PROCESS?
1. When you use one of our Websites or our social media channels, we process the following categories of personal data:
  - Technical information, such as information concerning your device, IP-address, browser type, geographical location and operating system;
  - Browsing behaviour, such as the length of your visit, the links you click, the pages you visit and the frequency with which you visit a page.
2. When you communicate with us by filling out a contact form on one of our Websites, or via e-mail, telephone, fax or social media channels, we process the following categories of personal data:
  - Identity information you provide us with, such as your first name, last name, gender, birth date, age, the company you work for, preferences and interests;
  - Contact details your provide us with, such as your e-mail address, postal address, country, telephone number and mobile telephone number;
  - Content of the communication, such as your request or question;
  - Technical information of the communication, such as with whom you communicate at our end, date and time of the communication;
  - Publicly available information about you, such as information publicly available on your social media profile;
  - Any other personal data you provide us with.
3. When you apply or enrol in the programme, we process the following categories of personal data:
  - Identity information you provide us with, such as your first name, last name, the company you work for, preferences and interests;
  - Contact details you provide us with, such as your e-mail address, postal address, country, telephone number and mobile telephone number;
  - Payment details, such as the amount you paid for the programme.
4. When you request more information, register for or participate in an event, or if you fill out any other form to which this Privacy Policy applies, we process the following categories of personal data (to the extent freely provided by you):
  - Identity information you provide us with, such as your first name and last name;
  - Contact details you provide us with, such as your e-mail address, postal address, country, telephone number and mobile telephone number;
  - Information necessary to process the registration, such as criteria needed to evaluate whether you fulfil the criteria for participation;
  - Payment details, such as the amount you paid for the programme;
  - Your photo if you pose for our photographer, or participate in a video interview, or provide a photo to us;
  - Any other personal data you provide us with (such as your feedback from participating in the programme).
5. When you fill out (or provide the information to fill out) a Narconon pre-assessment questionnaire, we process the following categories of personal data (to the extent freely provided by you):
  - Identity information you provide us with, such as your first name and last name and, if applicable, your relation to the person for whom you are looking for help;
  - Contact details your provide us with, such as your e-mail address, postal address, country, telephone number and mobile telephone number;
  - Basic information about drugs, such as the drug rehab programs that have been done in the past, the drugs used and brief history of the addict. However, we remind you not to provide us with any information revealing data regarding criminal offences, such as any prior drugs-related convictions;
  - Any other personal data you provide us with, such as whether you have ever received counselling other than for drug or alcohol use in the past.
6. Please note that the various categories described above may overlap or apply simultaneously. For example, if you fill out a questionnaire via one of our Websites, both Articles 4.1 and 4.3 apply. We receive most of your personal data directly from you, but it may happen that we receive additional information about your preferences and browsing behaviour from third-party partners such as Google. If you require more information about the personal data these third parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.
WHY AND ON WHAT LEGAL BASIS DO WE USE YOUR PERSONAL DATA?
1. In the table below, we explain the purposes for which we process your personal data and on the basis of which legal basis we do so. We rely on the following legal bases:
  - Your consent, in which you are informed of what this consent means before you freely give your consent;
  - A contract with you, in order to perform that contract or in order to take steps prior to entering into a contract with you;
  - A legal obligation that we have to comply with;
  - A contract with you, in order to perform that contract or in order to take steps prior to entering into a contract with you;
  - Our legitimate interest, such as continuous improvements of our Website, social media channels, materials and services to ensure that you have the best experience possible, to keep them safe from misuse and illegal activity, to disseminate and promote them and to make them available to you, including our social betterment and humanitarian programs.

	PURPOSE	LEGAL BASIS
1.	We process your personal data to send you promotional information for Narconon materials and services, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels if you explicitly consented to receiving such promotional information.	Your consent
2.	In the framework of sending you promotional information, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels, we process your personal data to collect information to analyse our promotional information, such as which of our content in those promotional information you have accessed or on which links in those promotional information you have clicked (e.g. via tracking technologies such as web beacons in our e-mails).	Your consent
3.	We process your personal data to create a unique profile of you to enhance your experience based on your location, your order history, your preferences, your interests, the content in our promotional information you have accessed.	Your consent
4.	We process your personal data in order to be able to process your order and to be able to deliver to you the materials or information you request or to provide you with the services you request.	A contract with you
5.	We process your personal data to provide you, in a personalized and efficient way with the materials, services or information you request via one of our Websites, e-mail, telephone, fax or social media channels.	Our legitimate interest
6.	We process your personal data: to comply with legal obligations that we have to comply with, or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities, or to transfer your personal data to the police or the judicial authorities upon our own initiative as evidence or if we have justified suspicions of an unlawful act or crime committed by you through your use of one of our Websites, our social media channels or other communication channels.	A contract with you
7.	We process your personal data to send you promotional information for materials or services similar to those you previously purchased or received from us, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels.	A legal obligation
8.	We process your personal data for other marketing purposes, such as on paper or via social media channels, i.e. to provide you with targeted promotional information, such as communications, promotions, offerings and newsletters of Narconon International and carefully selected partners. Also, we may publish your photo on one of our Websites or social media channels. If you do not agree, please do not pose for our photographer. If you would like to have a photo that has already been published removed, please contact our Data Protection Officer by sending an e-mail to dpo@able.org.	Our legitimate interest
9.	We process your personal data to perform statistical analyses in order to be able to improve our Websites, promotional information, materials and services or to develop new materials and services.	Our legitimate interest
10.	We process your personal data to preserve our legitimate interests or to preserve the legitimate interests of a third party in case your use of one of our Websites, our social media channels or other communication channels can be considered: a violation of any applicable terms of use of one of our Websites or the intellectual property rights or any other of our or a third party’s rights, or a danger or threat to the security or integrity of one of our Websites, our social media channels or other communication channels or any of our, our select partners’ or a third party’s IT systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.	Our legitimate interest

DO WE SHARE YOUR PERSONAL DATA?
1. We will never disclose your personal data to third parties outside ABLE or Narconon International without your consent or another lawful basis, unless we are legally obliged to do so. For example, we may rely on service providers to:
  - provide you our Website (such as a hosting provider); or
  - target our promotional information (such as a marketing company); or
  - process your order (such as a parcel deliverer to deliver you the materials); or
  - process your payment (such as a payment service provider or a credit checking agency).
  These third parties are only allowed to process your personal data on our behalf and upon our written instruction. We also warrant that all those third parties are selected with due care and are committed to observing the safety and integrity of your personal data.
2. With regard to any sensitive personal data, such as health-related information, processed in the context of a Narconon programme, we will never disclose such personal data to third parties outside ABLE International or Narconon International without your explicit consent, unless legally obliged to do so.
3. We may be legally obliged to share your personal data with competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
4. We do not send your personal data in an identifiable manner to any other third party than the ones mentioned in this article without your explicit consent to do so. However, we may send anonymized data to other organizations that may use those data for improving materials and services as well as to tailor the marketing, displaying and selling of those materials and services.
WHERE DO WE PROCESS YOUR PERSONAL DATA?
1. We process your personal data both within and outside the European Economic Area (EEA) and in the USA. In order to process your personal data for the purposes outlined above, we may also transfer your personal data to third parties who process on our behalf outside the EEA. We will not transfer your personal data to third parties that are not LegitScript certified, and each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. For ABLE International, such safeguards result from the fact that we are directly bound by compliance with EU legislation in the context of personal data protection. For third parties, such safeguards may be the consequence of:
  - The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
  - A contractual arrangement between us and that entity.
2. We may transfer anonymized and/or aggregated data to organizations outside the EEA. Should such transfer take place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.
WHAT QUALITY ASSURANCES DO WE COMPLY WITH?
1. We do our utmost best to process only those personal data which are necessary to achieve the purposes mentioned above.
2. Your personal data are only processed for as long as needed to achieve the purposes listed above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of one of our Websites. We will de-identify your personal data when they are no longer necessary for the purposes outlined above, unless there is:
  - An overriding interest of ABLE International, or any other third party, in keeping your personal data identifiable; or
  - A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying your personal data.
3. You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. We do this by customizing your unique profile based on relevant characteristics as outlined in Article 5 of this Privacy Policy and then use this profile to provide you with communications, promotions, offerings, newsletters and other promotional information about materials and services that may interest you..
4. We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by our staff members or third parties’ personnel will only be on a need-to-know basis and be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.
5. If you are registered to receive promotional information, such as communications, promotions, offerings and newsletters, via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such promotional information by clicking the opt-out link provided in such promotional information.
6. If you are registered to receive paper promotional information, such as magazines, communications, promotions, offerings and newsletters, you can object to receiving further promotional information on paper by submitting a request to our Data Protection Officer in accordance with Article 10 of this Privacy Policy.
WHAT ARE YOUR RIGHTS?
1. You may at any time request information about your personal data, rectification, erasure or restriction of your personal data and you may object to further processing thereof by contacting the Data Protection Officer via dpo@able.org.org.
2. More specifically, you have the right to request access to all personal data processed by us pertaining to you, meaning that you have the right to ask us for a copy of your personal data. We reserve the right to charge a reasonable administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request must specify which data categories you wish access to and for what processing activities.
3. You have the right to rectification, i.e to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.
4. You have the right to withdraw your earlier given consent for processing of your personal data.
5. You have the right to erasure, i.e to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against:
  - Our and third parties’ interests which may override your interests; or
  - Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
6. You have the right to restriction instead of deletion, i.e to request that we limit the processing of your personal data if:
  - We are verifying the accuracy of your personal data; or
  - The processing is unlawful and you oppose the deletion of your personal data; or
  - You require your personal data to establish, exercise or defend a legal claim, while we no longer need your personal data for the purposes listed above; or
  - We are verifying whether our legitimate interests override your interests if you exercise your right to object (see below).
7. You have the right to object to the processing of personal data for direct marketing purposes if:
  - There are justified reasons connected with your particular situation that warrant such objection; and
  - The processing is based on our legitimate interest and our legitimate interests do not override your interests.
8. You require your personal data to establish, exercise or defend a legal claim, while we no longer need your personal data for the purposes listed above; or
9. If you wish to submit a request to exercise one or more of the rights listed above, you can contact our Data Protection Officer by sending an e-mail to dpo@able.org. An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should meet the following conditions:
  - State clearly which right you wish to exercise; and
  - State clearly the reasons for exercising your right if such is required; and
  - Your request should be dated and signed; and
  - Your request should be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, we may ask you for your signed confirmation and proof of identity.
DATA PROTECTION OFFICER
1. If you have any questions about this Privacy Policy, please contact our Data Protection Officer by sending an email to dpo@able.org.