1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
1. IMPORTANT INFORMATION AND WHO WE ARE
Our website is not intended for children and we do not knowingly collect data relating to children.
Friends of Australian Wildlife Conservancy
121 Nassau St. 41B
New York, NY 10038
Telephone : 917-209-2194
Email : firstname.lastname@example.org
You always have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk) about how FoAWC collects and processes your personal data.
2. THE DATA WE COLLECT ABOUT YOU
When we use the term “personal data” we mean any information about you from which you can be identified. It does not include data from which your identity has been removed. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes your address for correspondence, email address and telephone number(s).
• Financial Data includes all the bank and other details, including credit card details, we need to collect your charitable donations to us, .
• Transaction Data includes details about charitable donations and legacy income we receive from you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, details of your charitable donations, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and interact with us.
• Marketing and Communications Data includes your preferences in receiving communications from us and our third parties.
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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect your personal data and you do not provide it, we may not be able to carry out the purpose for which we need your personal data. This could mean, for example, that we will be unable to accept your donation(s).
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different ways of collecting data from and about you, including through:
• Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms, including forms on our website, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Sign up to receive our quarterly newsletter; or
Donate to us.
• Third parties or publicly available sources. We will receive personal data about you from third parties as set out below:
Technical Data from the following parties:
(a) analytics providers [such as Google based outside the EU];
(b) advertising networks [such as [NAME] based [inside OR outside] the EU]; and
(c) search information providers [such as [NAME] based [inside OR outside] the EU].
Contact, Financial and Transaction Data from providers of technical, payment and Customer Relationship Management services such as Capsule, GivingMe, Virgin Money Giving and PayPal, all of which are based inside the European Economic Area (EEA).
Identity and Contact Data from Twitter, Inc., Facebook, Inc., YouTube, LLC and Instagram, Inc.
Identity and Contact Data from the Australian Wildlife Conservancy (for whom we raise money) or Friends of Australian Wildlife Conservancy Inc. (our sister charity in the United States who also raises money for the Australian Wildlife Conservancy), both of whom are based outside the EEA.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:
• You have given consent to the processing of your data to enable us to process charitable donations.
• We need to process charitable donations.
• You have given consent to the processing of your data to enable us to contact you.
• We need to contact you.
• It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• We need to comply with a legal obligation.
We will ask you for consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Set out below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
We have identified what our “legitimate interests” are where appropriate. These interests arise from our need to carry on our charitable operations as efficiently as possible. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests and our interests are overridden by the impact on you we will not use your personal data, unless we have your consent or are otherwise required or permitted to by law. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Further information is available from our data privacy manager.
We will always provide you with a choice around whether you want us to use your personal data for our fundraising activities.
We will ask you for an express opt-in consent before we share your personal data with any third party for fundraising purposes. Please note, however, that because of the way we carry on our charitable operations, most of the communications you receive from us will have been sent to you by the Australian Wildlife Conservancy (for whom we raise money). We ask you for your express opt-in consent to us sharing your personal data with the Australian Wildlife Conservancy when you sign up to our newsletter or to receive details of fundraising events or when you donate to us.
You can ask us or third parties to stop sending you communications at any time by contacting our data privacy manager. If you opt out of receiving these communications, your opt-out will not apply to personal data provided to us in connection with any donations you have already made.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is in keeping with the original purpose. Further information is available from our data privacy manager.
If we need to use your personal data for an unrelated purpose, we will let you know and explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with others for the purposes set out in the table above. For example:
• Service providers acting as processors based in Australia and the United States who provide IT, system and administration services to us, including the Australian Wildlife Conservancy (for whom we raise money).
• Professional advisers acting as processors or joint controllers including lawyers, consultants, bankers, auditors and insurers based in the United Kingdom who provide professional services and advice to us.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom to whom we are required by law to report processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We are a charity and we aim to minimise our administrative costs as far as we can by using external service providers, some of whom are based outside the EEA. We share your personal data with the Australian Wildlife Conservancy (for whom we raise money), for example. This involves transferring your data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure that the external service provider receiving it applies a similar degree of protection as is available in the EEA by entering into a contract with us that has been approved for use by the European Commission.
Further information is available from our data privacy manager.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an operational need to know and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if one occurs and where we are legally required to do so.
8. DATA RETENTION
FOR HOW LONG WILL YOU USE MY PERSONAL DATA?
We will only keep your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal data for a longer period where we receive legacy income, or in the event of a complaint, or if we reasonably believe there is a prospect of a dispute involving any donation(s) you have made to us.
To decide the appropriate retention period for personal data, we consider its volume, nature and sensitivity, the potential risk of harm from its unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal, regulatory, tax, accounting or other requirements.
By law, we have to keep basic information about our donors (including Contact, Identity, Financial and Transaction Data) for six years after they cease being donors, although we will aim to minimise the amount of basic information we keep where it is possible to do so.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For example, you may have the right to request access to, correction or erasure of your personal data, to request the restriction or transfer of processing your personal data, or to withdraw any consent you have given us. If you wish to exercise any of these rights, please contact our data privacy manager.
NO FEE USUALLY REQUIRED
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 could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to contact you and ask you for specific information to help us confirm your identity and your entitlement to exercise any of the rights listed above. This is a security measure to ensure that personal data is not disclosed to someone who has no right to receive it.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests as soon as possible. However, as a charity, we have limited administrative resources and occasionally it could take us some time to respond, particularly if your request is complex or you have made a number of requests. In this case, we will let you know and keep you updated.