Introduction and Overview
The Fund collects information you provide directly via the Service. The data we collect may include data that identifies you personally (whether alone or in combination). Some examples of data we collect include the following:
- Name and Contact Data: We collect such as your first and last name, postal address, e-mail address, telephone number, and other similar contact data.
- Credentials: We collect passwords, password hints, and similar security information for authentication and access.
- Demographic Data: We may collect information that you provide about your interests and activities, your gender and date of birth, nationality, and other demographic information.
- Payment Card Data: We collect data necessary to process your payment if you make a donation, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. To minimize any security risk, we do not store or retain your payment information.
- Donor Information: We collect information in connection with your donations, including how you found The Fund, your donation amount, and if you are making your gift in honor of anyone.
- Content: We collect the content of messages you send to us, such as feedback and information you provide to our staff. We also collect the content of your communications as necessary to provide you with the services you use.
The Fund collects information from our users at several different points on our Service, including:
- Various Registrations: In order to receive certain updates or use certain features of the Service, a user may have to complete a registration form. During registration a user is required to give their contact data. This information is used to contact the user about the Service. If asked for, it is optional for a user to provide demographic data.
- Newsletter: If a user wishes to subscribe to our newsletter, we ask for contact information such as name, address and email address. Users may opt-out of receiving future mailings as set forth in the section entitled “Your Rights and Choices” below.
- Event Attendance: If a user attends a Fund event, there may be an opportunity for a user to provide contact information and sign up to receive additional content or information about how to engage with the work of the Fund. Users may opt-out of receiving future mailings as set forth in the section entitled “Your Rights and Choices” below.
- Donations: If a user decides to donate to The Fund, we will collect donor information (including contact information such as name, address, and phone number) and payment card data or a copy of your check. We use outside credit card processing companies to process the payment card data. These companies are prohibited from retaining, sharing, storing or using your credit card information for any secondary purposes. Donors are also added to our newsletter and The Fund sends regular updates and solicitations to donors via email or mailing addresses provided by a donor. The Fund has offices in the US and UK and may transfer donor information between them. For more information see the section entitled “International Transfer” below. Donors may change their communication preferences at any time by emailing firstname.lastname@example.org or as set forth in the section entitled “Your Rights and Choices” below. If you need additional assistance, you can also contact us as set forth in the section entitled “Contact Us” below. The Fund respects the privacy of its donors and is committed to protecting their personal and otherwise sensitive information. We will not sell, share, or trade donor names with any organizations or third parties unless required by applicable law. We do not store credit card details nor do we share financial details with any 3rd parties.
- Referrals: The Fund encourages users to refer friends who may be interested in the Fund. If a user provides contact information of another potential user, the Fund assumes a legitimate interest in contacting the potential user. If the potential user is not interested, he or she can discontinue use of the Service and opt-out of receiving future mailings as set forth in the section entitled “Your Rights and Choices” below.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
For those users who interact with our Service online, we automatically collect certain information about your device and how your device interacts with our Service. We may use Services Providers to collect this information and other third parties may have access to this information as well. Some examples of data we collect include the following:
- Service Use Data: We collect data about the features you use, the time of day you browse, and the web pages and e-mails you visit.
- Device Connectivity and Configuration Data: We collect data about the type of device or browser you use, your device’s operating software, your device’s location, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, mobile Ad Ids (e.g., IDFA or AAID), and other device identifiers.
Logs, cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device fingerprinting, in-app tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Service or e-mails, including information about your browsing and activity behavior:
- Log Files: We store data about your use of the Service in log files, including your IP address to help analyze trends, administer the Service, track users’ movements, and gather broad demographic information for aggregate use.
- Web Beacons (“Tracking Pixels”): Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies which are stored on the user’s devices, web beacons are embedded invisibly on the Service and are about the size of the period at the end of this sentence. We may include web beacons in promotional or other e-mail messages or newsletters to determine whether you have opened the messages and the subsequent action taken by you.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your rights and choices regarding them, please see “Third Party Services, Features, and Devices” and “Your Rights and Choices” below.
Information Collected from Other Sources
- Social networks when you reference our Service or grant permission to us to access your data on one or more of these services.
- Partners with which we offer co-branded services or engage in joint marketing activities.
- Publicly-available sources such as open government databases or other data in the public domain.
- Paid for marketing and research information from third parties engaged by us to supplement our existing database and intelligence (as is customary in the marketing and charity industries). Please note that all marketing and research vendors are compliant with the General Data Protection Regulation of 2018.
For further information on Third Party Services, see the section entitled “Third Party Services, Features, and Devices” below.
We use information about you for our legitimate interests, including to:
- Manage our Service, including your donations.
- Authorize your access to the Service.
- Deliver the content and services that you have requested.
- Provide you with opportunities to engage with our work.
- Respond to your comments, questions, and requests, and provide you with customer support.
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Perform research and analysis about your use of, or interest in, our and third party content or services.
- Improve the Service or other Fund materials, websites, applications, marketing efforts, products and services.
We also use information about you with your consent, including to:
- Develop and display content, features, and advertising tailored to your interests on our Service as well as on other platforms and services.
- Send you advertisements and communicate with you about our and third party opportunities, events, and services that may be of interest to you.
- Fulfill any other purpose disclosed at the time you provide information and with your consent.
We may use information that does not identify you (including personal data that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
We also use your information to provide you with any service that we provide for you (to fulfill any obligations we may have to you under any contract for the provision of that service).
We want you to understand when and with whom we may share information collected about you through your use of our Service:
- Service Providers: We share your information with our agents, vendors, consultants and other service providers (collectively “Service Providers”) that perform certain services on our behalf. These services may include, among other things, fulfilling your donations, processing credit card payments, delivering content to you, authorizing your access to the Service, providing support, performing business and donation analysis, personalizing your experience on the Service, supporting our Service functionality, and supporting surveys and other features offered through our Service. These Service Providers have access to information needed to perform their functions, but are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
- Business Partners: When you engage in any fundraising activities, or educational briefings (“Opportunities”), we may share your information with other organizations with which we are partnering to offer you additional products, services, and/or Opportunities. All Opportunities that take place in collaboration with partnering organizations will clearly state this relationship in all materials on the Service (both online and offline). When you elect to engage in a particular Opportunity, we may provide your e-mail address and other information to a partnering organization. In addition, your information may be disclosed to third parties for administrative purposes and as required by law. By participating in an Opportunity, you agree to the official rules that govern that Opportunity, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
- Affiliates: The Fund has offices in the US and UK. In order to manage your relationship, any information you provide through the Service may be transferred or shared between the two entities. If your data is collected in the European Union, it will be transferred in accordance with European data protection laws (see section titled “International Transfer” below). Under some limited circumstances, the Fund may also share your information with organizations or representatives with which we partner to provide you with information about events and opportunities that might interest you.
- Security and Compelled Disclosure: We may share your information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. We may also share your information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms or other agreements or policies.
- Merger or Acquisition: We may share your information in connection with, or during negotiations of, a substantial organizational transaction, such as the merger, consolidation, or dissolution of the organization, or in the unlikely event of bankruptcy.
- Third Parties: We may share your information with third parties for purposes of facilitating your requests and providing you with advertisements, including those tailored to your interests.
- Consent: We may share your information for purposes disclosed at the time you provide the information and with your consent or at your direction.
We will not sell or rent your personal data to anyone. Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
Our Service contains content from and links to other websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). In addition, our Service contains features that allow you to interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”). For example, you use a Third Party Feature when you “like” or “share” content over social media through our Service. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature. If you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Service.
Our Service also contains Tracking Technologies operated by third parties. For example, we may use Tracking Technologies from analytics services, such as Google Analytics, on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, develop and display content and features tailored to your interests, and provide other services relating to Service activity and internet usage. We may also allow advertising agencies, ad networks, and other third parties to display advertisements on our Service, and use Tracking Technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements and Tracking Technologies. This information allows them to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).
For further information on Tracking Technologies and your rights and choices regarding them, please see “Information Collected Automatically” above and “Your Rights and Choices” below.
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 “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, take actions we deem necessary to protect the integrity of our Service or our users, comply with our legal obligations, resolve disputes, or take other actions otherwise permitted by law. European data subjects have additional rights set forth in “Your European Privacy Rights” below.
Tracking Technologies Generally
Most browsers automatically accept cookies, but you can usually modify your browser setting to decline or remove regular cookies. Browsers offer different functionalities and options so you may need to set them separately. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
If you choose to decline or remove certain Tracking Technologies, such as cookies, please note that you may not be able to use some of the interactive features offered on our Service. Also, when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Analytics and Advertising Tracking Technologies
You may exercise choices regarding receipt of Interest-based Advertising by submitting opt outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA“) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.
You can opt-out of receiving certain promotional communications (e-mails and push notifications) from us at any time by (i) for e-mails, following the instructions as provided in e-mails to click on the unsubscribe link, or sending an e-mail to us at email@example.com with the word UNSUBSCRIBE in the subject field of the e-mail; and (ii) for push notifications or in-app messages, adjusting the permissions on your mobile device.
Please note that your opt-out is limited to the e-mail address and device used and will not affect subsequent subscriptions or, for e-mails, non-promotional communications, such as those regarding service announcements, administrative notices, your donation information or transactions, or our ongoing business relations. Also note that opting out of receipt of promotional e-mail communications will only affect future activities or communications from us.
Your California Privacy Rights
California’s “Shine the Light” law permits customers in 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, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
The Fund may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. 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 “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.
Your European Privacy Rights
If you are in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through both online and offline components of the Service. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority.
Our Service is a general audience service, and not directed to children under thirteen (13) years of age. We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe we have collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA.
We implement and maintain reasonable administrative and technical security measures to help protect the loss, misuse and alteration of the information under our control. We use SSL encryption to help protect sensitive information online. We also implement and maintain reasonable physical measures to help protect user-information off-line. Learn more about how we store and maintain the information we collect by visiting our Records Retention page. No system can be completely secure. Therefore, we do not promise, and you should not expect, that your information will always remain secure.
Fund for Global Human Rights
The Fund for Global Human Rights
1301 Connecticut Avenue NW, Suite 400
Washington, DC 20036
Fund for Global Human Rights UK
17 Oval Way
London, SE11 5RR
European Specific Requests
For European specific requests, please contact Sarah Yarger, our Data Protection Officer at firstname.lastname@example.org