Effective Date: May, 2018
The definition of “personal information” will differ depending upon applicable law. In Europe it will include all information that directly or indirectly relates to you, and includes “personal data” as defined by the General Data Protection Regulation (GDPR). Where GDPR or other EU privacy laws apply to you, this Privacy Statement details how you can exercise your rights.
We will generally only collect and use your personal information when it is needed to process donations or to comply with our legal obligations.
We set out below a table where we describe each of the ways in which we use your Personal Information, the types of Personal Information that we use and the legal basis that applies to that use. Where the legal basis is “legitimate interest” we also set out some further details.
To allow you to register and attend an event and to follow up with you after the event
Identity data, Contact details, marketing & communication data, travel data
For electronic marketing/prayer communication
Identity data; contact details (email, sms etc); marketing & communication data
Consent or Legitimate Interest where it follows something you have donated
When you engage with us (for example, financially), the law permits Seed Company to send you relevant email marketing
For physical communication and non-marketing/prayer electronic communication
Identity data; contact details (telephone number, mailing address, etc); marketing & communication data
To keep you informed of our ministry; To send you ministry information and resources which we believe you will be interested in
To apply as a staff member or participate as a volunteer
Identity data; contact details; application data
For advocacy and fundraising
Identity data; Financial data; financial transaction data; contact details; contact details; marketing & communication data
To provide opportunities for you to partner with us through financial giving, communication or prayer
To process donations
Identity data; Financial data; financial transaction data; contact details; and tax status
Contract and Legitimate interests
To securely receive your donation toward our charitable aims
For statutory reporting
Identity data; contact details; tax status
Legal Obligations and Legitimate Interests
We may have obligations to report to the authorities in other countries
To improve our tools and improve your experience of our Systems, to maintain an audit trail of access to data, troubleshooting, data analysis, and system maintenance
Identity data; Historical transaction data; contact details; system data; audit logs; and location data; marketing & communication data; demographics
To manage, protect, and improve our Systems; to ensure that our services run effectively and to track who is accessing your data
To respond to complaints and requests
Identity data; contact details; historical transaction data; application data
Legal obligation and Legitimate Interests
To ensure that your concerns are addressed
We obtain personal information about you through:
We collect the following types of personal information:
Generally, we will not disclose or share your personal information (including your email address) with anyone outside our organization without your permission. However we may need to use or share your information with our partners and agents who provide goods and services to you on our behalf. Your information may be disclosed:
We take steps to safeguard your information and we have contractual provisions requiring all third party service providers to respect the security of your personal data and to treat it in accordance with our data protection policies and all applicable laws. We will not allow third party service providers to use your personal information for their own purposes and they will only be allowed to process your personal information in accordance with our instructions.
The following rights under the GDPR are available to you if you are located in the European Economic Area (EEA). If you wish to exercise any of these rights, please email us at email@example.com. We will respond to your request within 30 days of accepting it. Before accepting your request we may need to ask for some identity documentation from you, to make sure we don’t inadvertently provide your personal information to someone else.
Editing and updating personal information
If you find that your personal information needs to be edited or updated, you can change your personal information directly on the site. Our Systems offer different options for you to access, change, and modify the information you previously provided, such as your donor or customer record (for registered users only), email address, postal address, or to stop a duplicate email. If one of our Systems does not give you the option to edit personal information yourself or you wish to update the personal information we otherwise hold about you, you can ask us to update it by contacting us at firstname.lastname@example.org. Please make sure to provide us with all the information we need to be able to address your request, including both the old and new information.
Accessing personal information
You can request details of your personal information we hold. We will confirm whether we are processing your personal information and provide additional details including what kind of information we have about you, where we collected it, how we use it (including the legal basis for our processing), how long we expect to keep it, details of any automated decision making or profiling and the safeguards regarding data transfers to non-EEA countries, subject to the limitations set out in applicable laws and regulations. If you ask us, we will provide you with a copy of your personal information. We may charge you a fee to cover our administrative costs or if the requests are manifestly unfounded or excessive.
Deletion of personal information
At your request, we will delete your personal information if any of the following conditions are met:
We will review requests on a case by case basis and we might not be able to comply with your request if we need to process your personal information:
If this is the case, we will notify you of the reasons why your request was rejected.
Restriction of processing of personal information
ou have the right to request us to limit the processing of your personal information if:
To the extent needed, we may still keep some of your data to ensure we comply with your request to limit processing, or for other legal purposes.
Objecting to certain types of processing including automated decision making
Where we process your personal information based upon our legitimate interests, you have the right to object to this processing on grounds relating to your particular situation if you feel it impacts on your fundamental rights and freedoms. Where we process your personal information based upon our legitimate interests and where decisions are made by automated processing which has a legal or other significant effect on you, you may also object to such automated decision making.
Portability of personal information
You can request us to send you your personal information in a structured, commonly used, machine-readable format so that it can easily be transferred and used by a third party if:
We primarily rely on legitimate business interests to process your data, but to the extent we use consent to process your data, you have the right to withdraw any consent you may have given us at any time. We will comply with your request promptly. If you withdraw your consent, we might not be able to provide some of our products and services to you. At any point, you have the right to object to processing of your personal information for direct marketing purposes and we will promptly comply with your request.
Filing a complaint with a data protection authority
We will try to resolve any problems that you have but you are always able to contact your local data protection authority for assistance or to make a complaint.
We are an international organisation and we might need to transfer your personal information to other countries. If you are in the European Economic Area (EEA), please be aware that we may need to transfer your data to countries outside the EEA to process it. We will only transfer your personal information outside the EEA with adequate safeguards in place and in full compliance with applicable laws. For example, we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection. We have established standard contractual clauses with our service providers to ensure they protect your information and to enforce legal transfers of data internationally.
We have put in place appropriate security measures to protect your personal information from being accidentally lost, misused or accessed in an unauthorised way, altered or disclosed. These include technical, administrative and physical security measures to ensure that any information we collect is stored and processed securely.
For example, for Systems that require personal or sensitive data to be collected or displayed, a Secured Socket Layer (SSL) connection is required, to ensure that the data is encrypted as it is transferred to the browser. All credit card payments are processed using PCI compliant technology, to ensure that your credit card number is securely passed to the merchant/service provider. We do not store your credit card details.
We have procedures to deal with any suspected personal data breach and we will promptly notify you and any applicable regulator of a breach in accordance with our legal obligations.
We cannot guarantee that the security measures we implement in connection with the operation of the site will absolutely prevent others from accessing or acquiring any information that you provide while using the site. You can help us protect your personal information by properly protecting your password and remembering to sign out of your account and close your browser window when you finish visiting our site, especially if you are on a shared or public computer.
Most website browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience certain interactive features of the site or access all of the services provided through the site.
We keep your information as long as it is needed to achieve our purposes listed above, as well as for the amount of time necessary to meet any legal, tax, or reporting requirements.
We do not keep your personal information for longer than necessary and up to 7 years after your last interaction with us (e.g. making a donation or using one of our Systems). We may keep your data for longer than 7 years if we cannot delete it for legal or technical reasons. We may also keep it for statistical purposes. However, if we do, we will ensure that your privacy continues to be protected and only use it for these purposes.
We do not collect personal information from children under the age of 13 beyond what is necessary for them to participate in our online or other activities. If we discover that we have accidentally collected personal information from a child below the age of 13, we will delete it from our records as soon as reasonably possible.
If a child under the age of 16 attempts to register with one of our Systems, purchase products or materials, or participate in an activity requiring the submittal of personally identifiable information, a parent or guardian must give permission and consent for that child to provide information and register. The only personal information we collect from a child is information that is necessary for the child to participate in activities, such as an address for making a purchase. Parents have the right to request at any time that the information collected about their child is removed from our Systems.
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities). Please be aware that not all information sharing is covered by the “Shine the Light” requirements.
If you have any questions about this policy or the way we use your personal information, you may contact us at email@example.com.
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