Privacy Policy

Privacy Notice

At the Fund for Global Human Rights, we are committed to protecting and respecting individuals’ privacy. This notice explains what personal information we hold about you, how and why we process your personal information, your rights in relation to your personal information and how to contact us or make a complaint.

By ‘personal information’, we mean information which relates to you as an individual and tells us something about you. Our processing activities include collecting, storing, using and sharing your personal information.

For the purposes of this notice, Fund for Global Human Rights consists of two organisations: our US-based non-profit organisation – Fund for Global Human Rights (FGHR US); and our UK-based charity – Fund for Global Human Rights UK (FGHR UK). We will use these abbreviations where it is necessary to distinguish between our two organisations.

Section A of this notice applies only to individuals whose personal data is processed subject to EU and UK data protection laws as follows. All of FGHR UK’s processing of personal information is regulated under EU and UK data protection laws and FGHR UK is responsible as a ‘controller’ of personal information under those laws. In the same way, FGHR US is a controller under EU and UK data protection laws when it processes the personal information of EU-based individuals.

Section B applies to non-EU data subjects and those whose data is not subject to EU and UK data protection laws.

Section A: Rights and choices for UK and EU data processing

1. The personal information we collect and use

The personal information we collect, and the use we make of it, varies depending on our relationship with you. For that reason, this privacy notice distinguishes between our donors, grantees, suppliers and those who request information from us. Please be sure to read the sections of the privacy notice which apply to you.

2. Current and potential future donors

2.1 Personal information we collect about you

• Your name and contact details (telephone, email and address)
• Whether you are a UK taxpayer
• Information relating to your donations to us and/or other organisations
• Payment information such as your credit card or bank account details
• Biographical information about you such as your donation history, philanthropic interests, education history, sources of wealth and lifestyle choices. This information may be obtained from publicly available sources.

2.2 How we use your personal information

We use this information to:

• Administer your donations
• Keep you informed about our work, events and fundraising efforts
• Manage our fundraising effectively and tailor our marketing and fundraising communications with you
• Meet our legal and regulatory obligations.

2.3 Who we share your personal information with

Generally, we will not share your personal information outside Fund for Global Human Rights but there are some exceptions.

• Information supplied via our website is received initially by our website host company before being transferred to us.
• When you provide your financial information online, it is collected by the below vendors which process your donations on our behalf.  We do not retain this information ourselves:
  If you are based in the United States of America, your payment will be processed via PayPal
  If you are based in the United Kingdom and Europe, your payment will be processed via PayPal (Europe) S.a.r.l. et Cie, S.C.A.
• Our auditors and accountants may process your donation information, name and contact information for the purposes of conducting our annual audit.
• We will share your personal information with law enforcement or other authorities including tax authorities, the Charity Commission and Companies House, if required by applicable law.

2.4 How long we keep your personal information for

We retain your personal data in accordance with our data retention policy. In general, this is seven years after the end of your relationship with us.

Your financial information is retained only as long as necessary to process payments authorised by you and ensure we are complying with our legal and regulatory obligations.

2.5 The legal basis on which we collect and use your personal information

We may process your personal information on several legal bases including that:

• it is necessary for the performance of a contract between us and you or for the implementation of pre-contractual measures taken at your request
• it is necessary for us to comply with a legal obligation
• it is in our and your legitimate interests and the legitimate interests of those who benefit from receipt of our grants for us to administer your donations, keep you informed about our work, events and fundraising efforts and tailor our marketing and fundraising communications with you.

3. Grantees, and employees, volunteers or board members of grantee organisations

3.1 Personal information we collect about you

• Your name and contact details (telephone, email and address)
• Such biographical information as you supply us with
• Identity card information.

3.2 How we use your personal information

We use this information:

• To approve and administer the award of grants
• To coordinate travel
• For marketing purposes by publicising the work of the activists to whose organisations grants are made
• To nominate activists for awards
• To conduct due diligence and ensure that we do not breach economic or trade sanctions.

3.3 Who we share your personal information with

Grantee security is our top priority at the Fund for Global Human Rights, generally we will not share this information outside Fund for Global Human Rights but there are some exceptions.

• We may share the personal information of activists with donors and awarding bodies when we nominate them for awards or on our website and in our marketing material.
• Our auditors may process your financial information for the purposes of conducting our annual audit.
• We will share your personal information with law enforcement or other authorities including tax authorities, Companies House and the Charity Commission if required by US or UK applicable law.  In this event we will make every opportunity to contact you in advance of sharing this information.

3.4 How long we keep your personal information for

We retain your personal data in accordance with our data retention policy. In general, this is seven years after the end of your relationship with us.

3.5 The legal basis on which we collect and use your personal information

We may process your personal information on several legal bases including that:

• It is necessary for the performance of a contract between us and your organisation or for the implementation of pre-contractual measures taken at your organisation’s request
• It is necessary for us to comply with a legal obligation
• It is in our and your and your organisation’s legitimate interests and the legitimate interests of those who benefit from receipt of our grants for us to use your contact details to help administer the grant and your biographical details for marketing purposes.
• In some instances, we process your personal information on the basis of consent.

4. Vendors and potential suppliers

4.1 Personal information we collect about you

• Your name, contact details (telephone, email and address), employer organisation and job title. Some of this information may be obtained directly from your employer or via its website.
• Your financial information and purchase amounts (if you are a sole trader).

 

4.2 How we use your personal information

We use this information to communicate with you or your employer organisation regarding the provision of goods and services to us.

We use your financial information and purchase amounts to manage our accounts with you.

4.3 Who we share your personal information with

Generally, we will not share your information with anyone outside Fund for Global Human Rights and your employer organisation but there are some exceptions.

• Our auditors may process your financial information for the purposes of conducting our annual audit.
• We will share your personal information with law enforcement or other authorities including tax authorities, Companies House and the Charity Commission if required by applicable law.

4.4 How long we keep your personal information for

We retain your personal data in accordance with our data retention policy. In general, this is seven years after the end of your relationship with us.

4.5 The legal basis on which we collect and use your personal information

We may process your personal information on several legal bases including that:

• It is necessary for the performance of a contract between us and you or your employer or for the implementation of pre-contractual measures taken at your or your employer’s request
• It is in our and your or your employer’s legitimate interests that we can effectively administer the provisions of goods and services to us.

5. Information requesters

This section applies to you if you use our website or other means to ask us to send you email updates or other information.

5.1 Personal information we collect about you

• Your name and contact details (email and address)
• Other personal information provided by you.

5.2 How we use your personal information

We use your personal information to provide you with email updates and other information at your request or to answer your questions.

5.3 Who we share your personal information with

Generally, we will not share your information with anyone outside Fund for Global Human Rights.

5.4 How long we keep your personal information for

We will keep your personal information for as long as necessary to answer your query or for as long as you wish to continue receiving information from us.

5.5 The legal basis on which we collect and use your personal information

We process your personal information on the basis of our and your legitimate interests and the legitimate interests of those who benefit from receipt of our grants in our providing you with information about our activities and responding to your requests for information.

6. Transfer of your information out of the EEA

All of the data we collect is stored on servers compliant with GDPR regulations. If personal information of EU-based individuals provided via our website or collected by FGHR UK, this may be transferred to a server based in the US via FGHR US.  The same applies to personal information of US-based individuals collected by FGHR UK.  These transfers are made subject to EU standard contractual clauses which have been entered into between FGHR UK and FGHR US to ensure that our processing of your personal information is subject to the appropriate safeguards.

Some personal information is transferred to FGHR US via a third party which is also located in the US, for example, our website operator, or transferred by FGHR US to a third party located in the US. In those circumstances the transfer will be made only if the third party recipient of your personal information is compliant with GDPR regulations or has contracted with FGHR US or FGHR UK on the basis of the EU standard contractual clauses.

Copies of all EU standard contractual clauses governing these international transfers are available on request from dpo@globalhumanrights.org.

These transfers are made to ensure that we operate economically and efficiently and on the lawful basis that it is in our and your legitimate interests and the legitimate interests of those who benefit from receipt of our grants that we do so.

7. Your rights

7.1 Individuals whose personal data is processed subject to EU and UK data protection laws have a number of important rights free of charge. In summary, those include the right to:

• access your personal information and certain other supplementary information that this Privacy Notice is already designed to address;
• require us to correct any mistakes in your information which we hold;
• require the erasure of personal information concerning you in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that information to a third party in certain situations;
• object at any time to processing of your personal information for direct marketing;
• object in certain other situations to our continued processing of your personal information; and
• otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of those rights, including the circumstances in which they apply, see the ICO’s website which contains guidance on individual rights, currently found at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.2 If you would like to exercise any of those rights, please:

• email us at complaints@globalhumanrights.org
• let us have enough information to identify you;
• let us know the information to which your request relates.

7.3 If you would like to unsubscribe from any marketing material you receive from us you can do so by contacting us at complaints@globalhumanrights.org  or using the unsubscribe button on any electronic communications from us. It may take up to five working days for this to take place.

8. Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected information security breach. We will notify you and any applicable regulator of a suspected information security breach where we are legally required to do so.

9. How to complain and contact us

We hope that we can resolve any query or concern you raise about our use of your information.

Please contact us if you have any questions about section A of this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to complaints@globalhumanrights.org or write to us at:

Fund for Global Human Rights
Alexandra House
St. Johns Street
Salisbury
Wiltshire
SP1 2SB

You also have the right to complain to the UK Information Commissioner, who may be contacted at https://ico.org.uk/concerns/ or by telephone on: 0303 123 1113.  If you live or work outside the UK but within the EU or EEA, you can also complain to your local supervisory authority.

10. Changes to this privacy notice

We may change this privacy notice from time to time.  Please check it periodically.

Section B: Rights and choices for non-EU data processing

1. Correction/Updating Donation information

If you have a donated to us, you have the ability to review, update, and remove certain information you have voluntarily submitted to us in connection with your donation by contacting us as set forth in the section entitled “How to contact us” below. We may require additional information from you to allow us to confirm your identity. Please note that we may retain certain information associated with your donation for record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms, comply with our legal obligations, resolve disputes, or take other actions otherwise permitted by law.

2. Your California Privacy Rights

California’s “Shine the Light” law permits residents of California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, California residents can request to access certain information or opt in to, or opt out of, this type of sharing.

If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “How to contact us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that the Fund is not required to respond to requests made by means other than through the provided e-mail address or mail address.

3. How to contact us

Please contact us if you have any questions about section B of this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to complaints@globalhumanrights.org or write to us at:

The Fund for Global Human Rights
1301 Connecticut Avenue NW
Suite 500
20036
Washington D.C.