LAST UPDATED MAY 22, 2018
We take your privacy very seriously and are committed to protecting your personal information. Unless you agree otherwise, we will only use your email address for communications about the work of The Syria Campaign or issues related to it. We promise not to clog your inbox – we aim for just one or two emails a month to keep in touch and let you know about developments, and how you can take action. You can unsubscribe at any time.
We do not intend to, and do not knowingly, collect personal details about children on this site. If you are under 16 years old, always check with a parent or guardian before giving personal information to anyone online.
1. WHO WILL BE HOLDING YOUR PERSONAL INFORMATION?
1.2. Anyone who accesses our website will be able to see any information you make publicly available via the site. Other visitors to the website are subject to the website terms and conditions but we cannot guarantee that they will comply with them. Therefore, please do not disclose any personal information relating to you or anyone else when making any public contributions to the website.
1.4. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. INFORMATION WE COLLECT
2.1. Personal information means any information about a living individual from which that person can be identified. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. It does not include data where the identity has been removed (anonymous data).
2.2 The personal information that we collect from you may include, but is not limited to, the following information about you:
2.2.1. Identity Data includes first name, last name, data of birth
2.2.2. Contact Data includes billing address (where you are donating to us), email address, home address, telephone number, country of residence
2.2.3. Financial Data includes bank account and payment card details (where you are donating to us)
2.2.5. Profile Data includes your feedback, comments, survey response and donations
2.3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Technological Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.
2.4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HOW DO WE COLLECT INFORMATION?
3.1. We use different methods to collect data from and about you including through:
3.1.1. Direct interactions. You may give us your personal information by filling in forms or by corresponding with use by post, phone email or otherwise. This includes personal information you provide when you:
a) enquire about our activities, the website or us;
b) donate to us;
c) sign-up to receive updates on a campaign or our activities;
d) post comments or other content to the website;
e) contact us through the site or any other channel; or
f) sign a petition on the website.
3.1.3. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. HOW WE USE THIS INFORMATION WE COLLECT
4.1. We will only use your personal information as permitted by law. Most commonly, we will use your personal information in the following circumstances:
a) to help you participate in the website;
b) to provide you with any information you have requested;
c) to provide or administer activities relating to our services or the services offered on the website;
d) to display any comments you make on the website;
e) when you sign a petition or make a comment when signing a petition, your first name, country and comment may appear on our activity stream (on a petition page);
f) to provide you with information relating to us or information that we think might be of interest to you including information about our events and activities;
g) to process any donations that you make to us;
h) to maintain our organisational records;
5. LEGAL BASIS FOR PROCESSING
5.1.1. To perform our contract with you when you register as a donor and/or sign a petition;
5.1.2. To comply with our legal obligations, including those laid down in accounting, tax and company laws;
5.1.3. To pursue our or a third party’s (such as our service providers, agents or delegates) legitimate interests which do not override your interests or fundamental rights and freedoms, such as (i) mitigating business and operational risks; (ii) complying with internal policies; (iii) sharing information between The Voices Project and The Voices Project USA]for administrative purposes; (iv) [investigating, detecting and preventing fraud and other crime;] (v) ensuring network and information security; (vi) purchasing services from third parties which support us in providing our services to you and in complying with our legal obligations; (vii) developing, improving and informing you about our services and other products and services that may be of interest to you; (xiii) maintaining the relationship and otherwise interacting with you; (xiv) protecting our interests, including the establishing, exercising and defending legal rights and claims; and (xv) ensuring that our service providers, agents and delegates can also comply with their legal and regulatory obligations. When evaluating whether legitimate interest can be relied on as a legal basis for the processing activities described above, a balancing test is carried out to ascertain whether the use of your personal information would be overridden by your interests or fundamental rights and freedoms;
5.1.4. In certain circumstances and subject to applicable laws, your consent, however we will make this clear to you at the time of collection of your personal data, and you will have the right to withdraw your consent at any time. Generally, we rely on consent as a legal basis for processing your personal information only in relation to sending direct marketing communications to you via email or text message
5.2. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
5.3. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
6. HOW WE SHARE YOUR INFORMATION
6.1. If you add your name to a petition, upload any content or post any comments to our site that information will be available publicly on the website.
6.2. We may use carefully selected service providers, agents and delegates to process your information on our behalf, such as software providers to host the website. Such third parties will only be authorised to use your information to fulfil their contractual obligations to us as a processor, in accordance with our instructions, and will not be permitted to use it for any other purpose. We will ensure that they put in place appropriate technical and organisation security measures to adequately protect your personal information and we will retain full responsibility for such personal information.
6.3. In exceptional circumstances, we may share your information when we are legally required to do so.
6.4. International Transfers. The Voices Project may share your personal information with our campaign counterparts in the US The Voices Project USA, so this will involve transferring your personal information outside the European Economic Area (EEA).
6.5. Many of our service providers are based outside the EEA and this will involve a transfer of your personal data outside the EEA.
6.6. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by using standard data protection contracts approved by the European Commission, which give personal information the same protection it has in Europe, where the level of protection of personal data in those countries has not been deemed adequate by the European Commission.
7. HOW WE PROTECT PERSONAL INFORMATION
7.1. We have appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an authorised way, altered or disclosed. In addition, we limit access to your personal information to those, employees, agents, service providers, contractors and other third parties who have a business need to know.
7.2. Despite all of our precautions however, no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we strive to protect your personal information, we cannot guarantee the security of any information which you disclose to us and you must understand that you do so at your own risk.
8. CHANGES TO YOUR DETAILS OR THIS POLICY
8.2. It is important that the personal information we hold about you is accurate and current. If your personal details change, please help us to keep your information up to date by notifying us at the email address: [email protected]
9. DATA RETENTION
9.1. We will only retain your personal information for as long as necessary to fulfil the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2. To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
10. YOUR LEGAL RIGHTS
10.1. Under certain circumstances you have rights under data protection laws in relation to your personal information. You have the right to:
10.1.1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
10.1.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
10.1.3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
10.1.4.Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as your feel it impact on your fundamental rights and freedoms. You also have the right to object were we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
10.1.5. Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
a) if you want us to establish the data’s accuracy;
b) where our use of the data is unlawful but you do not want us to erase it;
c) where you need use to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
10.1.6. Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
10.1.7. Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
10.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.4. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. California Privacy Rights – Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of this information or to opt out of these disclosures, please contact us as indicated below.
12. CONTACT US
If you have any questions or comments, please let us know by contacting our team at [email protected] or by phone [+1 267 714 6088].
We also have a data privacy manager for questions in relation to your data:
Name: Kate Staff
Address: 594 Dean Street, Floor 2, Suite 22, Brooklyn, NY 11238 USA
Email Address: [email protected]
You have the right to make a complaint at any time to an appropriate EU supervisory authority. The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.
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