Introduction and general terms
Data Friendly Space (DFS) promises to take great care with your personal data. We commit to protecting any personal information we obtain about you and we promise not to share that information with anyone without you permission. We are data people and we get it.
Data Friendly Space is a registered 501c3 Non-profit corporation in Virginia, USA. This Privacy Policy relates to information which is obtained by DFS and for which DFS is the Data Controller. That is to say, data for which DFS sets the purpose of the use as well as the how this data will be used.
We may hold and process data for a number of reasons:
- To send our supporters marketing information about our projects, fundraising activities, and appeals where we have their consent;
- To claim gift aid or impact metrics for donors who request traffic and demographic data;
- To keep people safe, whether they are contractors, staff, or the focus of projects;
- To comply with legal obligations;
- To manage our organization;
- To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted.
These reasons are underpinned by a “legal basis” under GDPR.
The law on data protection, particularly in the E.U. where many of our partners are located, sets out a number of different reasons for organizations to collect and process your personal data: When collecting your personal data, we will always make clear to you which data, if any, is necessary for a particular purpose.
DFS relies on the following legal bases in our marketing activities:
Consent
Wherever possible, we will ask for your consent to send you marketing and promotional information. We will do this through a clear statement of what you will receive and allow you to select only those channels that you wish to hear from us by.
Legitimate interest
In specific situations, we process your data to pursue our legitimate interests in ways which might reasonably be expected and which do not materially impact your rights, freedom or interests. DFS’s use of legitimate interest includes the following:
Sending direct marketing information to you;
If you have opted in to DFS emails, we may use your details to link to your account on Facebook or other social media sites in order to serve you DFS content. It’s a connected world;
To help identify partner organizaitons who may wish to engage with DFS with a particular emphasis on humanitarian NGOs.
For activities other than marketing, we may rely on different legal bases:
Legal compliance
If the law requires us to, we may need to collect and process your data.
Public Interest
In limited situations, we may use data in the public interest. It is likely to be in the public interest to collect data to prevent crime or dishonesty, ensure that we are fair in our practices by carrying out equality and diversity monitoring, or safeguard the wellbeing of people with whom we work. Our work often includes marginalized communities and migrants and a corporate value of DFS is the protection of people. We don’t apologize for that.
Marketing Information
DFS will only contact you to keep you up to date on our work, or let you know of ways in which you or an institution you are engaged with can support that work. We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work. We will also ask you about the ways in which you would like to receive this information but it will most likely be email given our work across so many regions of the world.
We may ask you to reconfirm your consent if we have evidence that suggests you may no longer wish to hear from us. We will never send you marketing material if you have told us that you do not wish to receive it.
“Legitimate Interest”
We will not use “legitimate interest” if you have opted out of direct mail or unsubscribed from emails.
Personal Information
DFS may collect your personal data in the following circumstances:
When you access DFS’s Social Media
We might obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
https://www.facebook.com/policy.php
https://twitter.com/en/privacy
https://www.whatsapp.com/legal/#privacy-policy
https://www.linkedin.com/legal/privacy-policy
When the information is publicly available
We might also obtain personal datppza about individuals who may be interested in partnering with organizations like DFS. In this scenario, DFS may seek to find out more about these individuals and their interests and motivations for giving through publicly available information. This information may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from publicly available databases.
DFS will not retain publicly available data relating to potential donors without their consent, which will be sought at the earliest practical opportunity. While we are grant and contract based, we are always looking for innovation funders eager to have a social impact using data.
We may also gather information if your activities relate to our work – for instance, if you are a public figure such as an elected official or you represent an organization which we work with or which is related to one of our projects we may gather information about you in order to inform our project or even extend the funding of the initiative.
When we use cookies
Cookies are a useful way for us to understand how supporters use our websites.
When you visit our web sites, we may collect data from your computer or other device such as a smart phone or tablet through the use of “cookies”. Cookies are created by your web browser when you visit our website. Every time you go back to DFS websites, your browser will send the cookie file back to the website’s server. They improve your experience of using our website, for example, by remembering your preference settings so that you are presented with information likely to be most relevant to you, and by measuring your use of the website to enable us to continuously improve our website to ensure that it meets your needs.
Cookies can also be used to show you relevant DFS content on social media services such as Facebook – these are known as “retargeting'” cookies.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), DFS may still collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device). We don’t mean to be creepy but it helps us to know who is new to us and who likes to read about our work more often.
Other Websites
The DFS website contains hyperlinks to websites owned and operated by other organizations. These may include other media organizations, research organizations, aid agencies, and think tanks. These third-party websites have their own privacy policies, including policies on their use of cookies, and we urge you to review them. They will govern the use of personal information you submit, or which is collected by cookies while visiting those websites. We cannot accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.
What DFS May Collect
DFS may collect personal data relevant to the type of interactions you have with DFS. Whatever your interaction, which we hope is positive, the information will be minimal and linked to the purpose for which we need it.
For instance, if you apply for a role with us, we may collect this data for equality monitoring.
Rarely, we may collect this data for the prevention of crime or dishonesty, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this, we will do it carefully and in accordance with applicable laws.
All sensitive personal data is stored on a secure database, to which only a limited number of relevant parties have access.
We will not Share your Information
We will only use your information within DFS for the purposes for which it was obtained. DFS will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities, or other organizations as a result of you engaging with us online or offline.
Facebook and other social media sites
We may use your email address to match to your account on Facebook, LinkedIn, or other social media sites in order to show you DFS content while using these services. No data we hold about you is retained by the third party, though the third party may have its own data privacy policies which you should review.
Facebook: https://www.facebook.com/help/568137493302217
LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931
Where legally required
We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies, statutory bodies, or law enforcement agencies for purposes in the public interest or the prevention and detection of crime, subject to appropriate protection in law).
We will hold your personal information on our systems for as long as is necessary for the relevant activity.
Where you contribute material to us, e.g. user generated content such as a message board or a contact us link, we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.
Keeping Data Safe
We ensure that there are appropriate technical controls in place to protect your personal details. For example, our online forms are always encrypted and our network is protected and routinely monitored.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors who are all required to sign non-disclosure contracts with DFS.
Your Data Rights
You have a variety of rights with respect to your data, including the rights to see, update, restrict, object to the use of or withdraw use of your data. In particular, depending upon why we hold your data, you may have the right to request:
- Access to the personal data we hold about you, if any, including how we first obtained your details (this is known as a ‘Subject Access Request’).
- That we delete your personal data from our systems (this is known as the “Right to be Forgotten”).
- That we no longer process your data automatically to decide whether particular marketing activities are likely to be of interest or suggest an appropriate donation level based on your previous donation history. This is known as profiling and helps us to ensure that our marketing is relevant and appropriate.
You can contact us to request to exercise these rights at any time.
Right to be Forgotten
Upon request, we will delete your personal data from our systems, to the extent that we are permitted to by law or regulatory guidelines.
Opting out of profiling
Upon request we will cease using your personal data to decide whether you would be interested in particular updates and content.
Subject Access Requests
You have the right to request a copy of the personal information we hold about you, if any. We will provide this as soon as possible, and within a month unless there are specific reasons why this would not be possible. We will always let you know if this is likely to be the case.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the DFS Board of Directors.
Changes to these Policies
This Privacy Policy may be updated from time to time so you may wish to check it each time you have questions about the kinds of data and cookies DFS may be using.
If you do not agree to the changes DFS has made, please do not continue to use the DFS website. If material changes are made to the Privacy Policy we will notify you by placing a prominent notice on the website.
