Welcome to sfcg.org, LoveAnyway.shop, and LoveAnyway.com, websites available at https://sfcg.org, and https://loveanyway.com, respectively, (the “Sites”).
The Sites and related services are owned and operated by Search for Common Ground (“Organization,” “us,” “we,” “our”). We know that you care how Personal Data about you is used and shared. Pursuant to the applicable Personal Data protection legislation, including the European General Data Protection Regulation (“GDPR”) 2016/679 and the relevant national legislation, we have developed this Privacy notice(“Privacy notice”) to inform donors and website visitors/users (“User(s),” “you,” or “your”) about how we collect Personal Data in the course of conducting our business, including on the Sites, how we use the collected Personal Data , and User’s rights with respect to the collected Personal Data .
In this Notice:
- “SEARCH FOR COMMON GROUND” : the international non-profit association SEARCH FOR COMMON GROUND, located at 205 Rue Belliard, 1040 Brussels, Belgium.
- “Data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
- “Processor” means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the data controller.
- “Personal Data” or “Data” means any Personal Data relating to a natural person who can be identified or is identifiable directly or indirectly, in particular by reference to an identifier, such as a name, identification number, location data or online identifier (…);
- “Processing of Personal Data” or “Processing of Data” means any operation or set of operations which is performed upon Personal Data or sets of data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Cross-border transfer” means either:
(a) processing of Personal Data which takes place in the context of the activities of establishments in more than one European Member State of a controller or processor in the European Union where the controller or processor is established in more than one European Member State; or
- (b) processing of Personal Data which takes place in the context of the activities of a single establishment of a controller or processor in the European Union but which substantially affects or is likely to substantially affect data subjects in more than one European Member State.
- “European Economic Area” (“EEA”): all member states of the European Union including Iceland, Liechtenstein and Norway.
This Privacy Notice is applicable to all those who access, visit, and/or use our Sites, including donors. Please read this Privacy Notice carefully. This Privacy notice is incorporated into our Terms of Use and Website Cookie notice. Your use of our Sites and any Personal Data you provide through the Sites are subject to this Privacy Notice at all times.
Data Controller
Within the framework of its activities, SEARCH FOR COMMON GROUND is required to process your Personal Data in its capacity as Data Controller insofar as it determines the means and purposes of the processing activities.
Contact details of the Data controller:
- Name: SEARCH FOR COMMON GROUND
- Email: [email protected]
- Website: www.sfcg.org
- Postal address:
SEARCH FOR COMMON GROUND
To the Director of Finance & Administration
Rue Belliard, 205
1040 Brussels
Belgium
Data Protection Officer (‘DPO’)
We have appointed a Data Protection Officer (“DPO”) within SEARCH FOR COMMON GROUND.
The mission of the DPO is to inform any data subject about the Personal Data that is processed about him/her. He provides advice and ensures compliance with current regulations, in particular the GDPR.
You can contact the DPO for any question relating to the processing of your Personal Data and the exercise of your rights.
For EU citizens or residents, please contact our DPO with the following contact details:
- Email: [email protected]
- Telephone: +32 2 778 01 00
- Postal address:
BDO Brussels (Airport)
The Corporate Village
Da Vincilaan 9 – Box E.6
1930 Zaventem
BELGIUM
For US citizens or residents, please contact our DPO with the following contact details:
- Email: [email protected]
- Postal address:
Search for Common Ground
1730 Rhode Island Ave NW, Suite 1101,
Washington, DC 20036,
USA
How we collect Personal Data
When you use the Sites, we collect and/or process the following types of data:
Personal Data
As defined above in this privacy notice, “Personal Data” means any Personal Data relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, for example by reference to an identifier. We collect Personal Data that you provide to us in particular when you register for an Account (as defined below) on our Sites; submit a donation; make a purchase; subscribe to one of our newsletters; contact us via phone, email, postal mail, or other means; chat with us on our Sites; register to events we organize or respond to our communications to you (e.g., non-anonymous surveys, requests for feedback). This may include your first or last name, email address, social media usernames, telephone number, mailing address, billing address, payment Personal Data, organization name, geolocation Personal Data or your IP address. We may also collect Personal Data such as gender, nationality, ethnic origin (in some cases and for US residents only), interests or preferences, business or company Personal Data , professional experience, image (photos/videos), educational background, professional or personal reference, contact Personal Data or social media URLs. Some Personal Data may be used in Account or password recovery processes.
We also collect some legal information about donors (judicial data related to criminal records) and/or government watchlists as prescribed by local law and donor regulations.
When signing up for the newsletter, we may collect and process your surname, first name, phone number and email address.
In the European Economic Area (“EEA”), Personal Data includes an identification number, location Personal Data , and/or an online identifier.
We collect Personal Data that may include Personal Data about your use of the Sites including chat interactions on the Sites (including text exchanged during the interactions), donation amounts and frequencies, items purchased, purchase histories, Personal Data you post or otherwise submit to the Sites, or emails you send to us. We also use Fundraise Up, Google Analytics, and automated chat and email marketing software to provide services and website functionality to Users.
Personal Data that we collect may also include “Log Data.” Log Data refers to certain Personal Data about how a User (including both Users with an Account and without an Account) uses our Sites. Log Data may include the pages or features of the Sites to which a User browsed and the time spent on those pages or features, the frequency with which the Sites are used by a User, search terms, the links on our Sites that a user clicked on or used, and related timestamps.
We may also determine location Personal Data about you based on Personal Data in your Internet connection data or provided by your ISP (e.g., your IP address). Under the European law, IP addresses and online identifiers are considered as Personal Data. You may be given the option to receive push notifications while using our Sites. In order to serve push notifications, we may need to collect your IP address and a persistent identifier from your device. You can turn off push notifications in your device settings.
We use automated Personal Data collection tools, such as cookies and web beacons, to collect certain types of Personal Data. For more Personal Data on cookies and how the Services use cookies, please read our Cookie notice.
If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Sites, we may receive your Personal Data and other Personal Data about you and your computer, mobile, or other device that you have made available to those social networking services, including Personal Data about your contacts through those services. For example, some social networking services allow you to push content from our Sites to your contacts or to pull Personal Data about your contacts so you can connect with them on or through our Site. Some social networking services also will facilitate registration or enhance or personalize your experience on our Sites. This includes if you “follow,” “like,” or link your social networking account to our Sites. Your decision to use a social networking service in connection with our Sites is voluntary. However, you should make sure you are comfortable with the Personal Data your third-party social networking services may make available by reviewing Privacy notices of those providers and/or modifying your privacy settings directly with those networking sites/services.
If we combine or associate Personal Data from other sources with Personal Data that we collect through the Sites, we will treat the combined Personal Data as Personal Data in accordance with this Privacy notice.
Non-Personal Data
“Non-Personal Data” does not identify you, but provides insights regarding your use of the Sites. We collect Non-Personal Data that may include non-identifiable information Personal Data about your use of the Sites, including but not limited to, Internet connection Personal Data, computer equipment Personal Data, web browser specifications, websites visited before accessing our Sites, websites visited after leaving our Sites, other similar information Personal Data about traffic and usage as you navigate to, through, and away from our Sites.
In some jurisdictions, such as the United States, an IP address may be considered Non-Personal Data. In the European Economic Area, for example, an IP address is considered Personal Data under applicable data protection laws. If this is the case, we process Non-Personal Data for the same purposes as Personal Data under this Privacy notice.
ON WHICH LEGAL BASIS WE PROCESS YOUR PERSONAL DATA
For Legitimate Interests. Your Personal Data is used in line with our legitimate interests and in accordance with your interests and rights. We collect Personal Data via web pixels and cookies to store your preferences, secure our Website, improve website navigation, make personalized features and other services available to you, generate statistical Personal Data, monitor and analyze user traffic and usage patterns. We also process your Personal Data to monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve our products, services, materials and other content that we describe or make available through the Sites, and otherwise help administer and improve the Sites.
Legal or regulatory obligation. We are legally obliged to process and communicate certain Personal Data to the competent authorities and bodies, such as the Data Protection Authority (“DPA”) or financial bodies.
Performance of a contract. The use of your Personal Data is necessary for the conclusion or performance of a contract you have entered into with us or as part of the provision of a service.
Consent. We have obtained your free and explicit consent to use your Personal Data for a specific purpose. For example, by signing up to our newsletter and ticking the appropriate box, you are giving us your consent to process your Personal Data as described in this Notice. If we process Personal Data based on your consent, we will inform you that you have the right to withdraw your consent at any time by contacting us (see below). In addition, we use third‐party e‐mail providers to deliver communications to you. This is an opt-in e-mail program. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications through the “Update your preferences” link in our emails or by contacting us at [email protected].
We may, from time to time, invite you to participate in online surveys. The Personal Data requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and the Sites. The Personal Data collected by these surveys is used to research market trends, company growth, community needs, etc. Your input will help us to improve customer experience and shape development of our products and Services.
Why we collect and use Personal Data
Except as otherwise stated, we may use Personal Data we collect from you for the following purposes :
- operating, maintaining, and providing to you the features and functionality of our Sites;
- send you Sites-related notices, including notifications about our Sites or Organization, newsletters, changes to the Sites or Organization, or other Personal Data ;
- give information about the Organization and our activities to Users;
- securing our Sites;
- establishing Accounts for Users to use the Sites;
- validate your username, e-mail, password, and/or other login credentials;
- customizing the Sites-related content to your preferences;
- responding to your requests and provide user support;
- processing your donations to us;
- using Social media in order to increase our visibility on the Internet and ensure proximity to our current and future Users or donors;
- providing you with merchandise or services you have requested or purchased from us;
- evaluating and improving the content of our Services;
- checking on your Account status and maintaining record of activities in connection with your use of the Sites;
- evaluating job candidates;
- processing your requests to get involved with the Organization, including signing up for volunteer opportunities;
- enforcing our agreements, terms, conditions, and policies;
- working with our service providers who perform certain business functions or services on our behalf and;
- preventing or investigating fraud or other violation of policies/ misconduct (or for risk management purposes);
- complying with a legal obligations, court order, or in order to exercise our legal claims or to defend against legal claims;
- conducting aggregate or research analysis and developing business intelligence that helps us to enhance, operate, protect, make informed decisions and report on the performances of our Sites;
- notifying of contest or sweepstakes results;
- registering for the events we organize;
- sending e-mail and postal mail supplying the most recent service Personal Data or sending you Personal Data about an order (e.g., order confirmations, shipment notifications, etc.); and
- notifying you of any changes to relevant agreements or policies (including, but not limited to, this Privacy notice, our Terms of Use, or our Cookie notice).
If you are a user accessing our Sites from within the EEA and we have collected your Personal Data (such user herein referred to as a “Data Subject”) and we have obtained your consent, we may also use your Data in the following ways; and, if you are a citizen of any other jurisdiction, you acknowledge that we may use your Personal Data in the following ways:
- to share your Personal Data with our corporate parents, subsidiaries, other affiliated entities, and associated entities;
- to send e-mail and postal mail to provide you with updates and news;
- to process any request you make; and
- to process the commercial transaction for which you provided Personal Data .
WHERE YOUR PERSONAL DATA ARE STORED
Search for Common Ground operates around the world. This means that your Personal Data may be processed and transferred to countries outside of the European Economic Area (EEA) and the European Union (EU) whose laws may not provide the same level of data protection. The Sites are hosted and operated in the United States. If you use the Sites from outside the United States, please be aware that the Personal Data you provide to us is transmitted to, processed, and stored in the United States.
Search for Common Ground undertakes to put in place appropriate safeguards to ensure that a level of protection equivalent to that in force in the EEA/EU is guaranteed, in accordance with Chapter V of the GDPR.
How and with whom we Share your Personal Data
We share your Data in the following ways:
- We will not sell or rent your Personal Data to third-parties.
- We may store portions of your Data in locations outside of the direct control of the Organization (e.g., on servers or databases co-located with service providers).
- Any Data that you voluntarily disclose for posting to the Sites becomes available to the public. In some cases, this posted Data may be controlled by privacy or website customization settings. If you remove Data that you posted to the Sites, copies may remain viewable, for example, in cached or archived pages or if other Users have copied or saved that Data.
In general, your data will only be processed by the relevant department within our Organization. When necessary, we may share your Personal Data with affiliated entities/group companies.
We may share your Data with the following parties:
- Service providers that help us administer and provide the Sites (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Data only for the purpose of performing services on our behalf. We require that any third-party service providers limit their use of your Data solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Data and not make unauthorized use or disclosure of the Personal Data. A list of service providers is provided in Section 4, below;
- Authorized third parties, who are parties directly authorized by you to receive the applicable Data, such as when you authorize a third-party application provider to access your Account. The use of your Data by an authorized third party is subject to the third party’s privacy notice;
- Certain third parties that provide us with grants. In some cases, these third parties ask us to identify the top Users or organizations that donate to us. Whenever we share Data with these grant-providing third parties, we enter into agreements with these third parties that they keep the Data received from us confidential and that they use the Data only for the purpose of providing us with grants.
- Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we will require the recipient to use such Personal Data in accordance with this Privacy notice;
- As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact Personal Data (e.g., name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and
- Pursuant to your express consent.
- Donors. If you choose to make a donation, whether through features on the Sites or through other means made available by us, we will not share, sell, or rent your Personal Data to third parties except as necessary for purposes of processing the payment such as credit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. We also will not use any Personal Data you provide to us to send you mailings on behalf of third parties.
- Third party service providers. We use third-party service providers to help us operate our Sites, who may collect, store, and/or process the Personal Data detailed herein. We allow access to our Sites and databases by third parties that provide us with services, such as technical maintenance, market research, shopping functionality, and ads functionality, but only for the purpose of and to the extent necessary to provide those services.
We use commercially reasonable efforts to engage with third parties that post a Privacy notice governing their collection, processing, and use of Personal Data. While we may seek to require such third parties to follow appropriate privacy policies and will not authorize them to use this Personal Data except for the express purpose for which it is provided.
We use the following third-party service providers:
Salesforce Marketing Cloud. We use Marketing Cloud e-mail marketing services to send mass communication e-mails to Users. We track how Users open these e-mails and what links they click so that we can better serve customers with services and Personal Data that they find relevant. When you “subscribe” to one of our mailing lists, you agree to receive e-mails and other Personal Data from us. Upon receiving an e-mail from us, you may choose to opt-out of future e-mail messages, in accordance with the CAN-SPAM Act of 2003 or similar European specific legislations by clicking the “Update your preferences” option at the bottom of our e-mails and following Active Campaign’s simple opt-out procedure. You can learn more about Active Campaign’s privacy policies at its website https://www.salesforce.com/company/privacy/ .
Drip. We use Drip e-mail marketing services to send mass communication e-mails to Users. We track how Users open these e-mails and what links they click so that we can better serve customers with services and Personal Data that they find relevant. When you “subscribe” to our mailing list, you agree to receive e-mail advertisements and other Personal Data from us. Upon receiving an e-mail from us, you may choose to opt-out of future e-mail messages, in accordance with the CAN-SPAM Act of 2003 or similar European specific legislations by clicking the “Update your preferences” option at the bottom of our e-mails and following Drip’s simple opt-out procedure. You can learn more about Drip’s privacy policies at https://www.drip.com/privacy.
Meta and Meta Pixel and Retargeting. We use Meta’s conversion tracking pixel and retargeting service(s) to monitor Users who are redirected to the Sites after clicking on a Meta ads. This allows us to monitor our ads and their effectiveness. Meta explains conversion tracking on its website https://www.facebook.com/business/a/online-sales/conversion-tracking, and Meta explains its use of cookies and other storage technologies, as well as how to control Meta’s use of cookies, on its site here https://www.facebook.com/policies/cookies/.
Fundraise Up. We use Fundraise Up to process online donations and provide Users with a secure, seamless giving experience. Fundraise Up collects information that Users voluntarily provide when making a donation, such as name, email, payment details, and donation amount. This data is used to process transactions, issue receipts, and improve the donation experience. Fundraise Up may also use cookies or similar technologies to remember User preferences and streamline future donations. You can learn more about Fundraise Up’s practices by reviewing their Privacy Policy at https://fundraiseup.com/privacy/.
Google Analytics. We have enabled Google Analytics to collect data about our traffic through the use of Google Advertising cookies and other anonymous identifiers. We use Google Analytics cookies and other cookies to compile data to better understand Users and provide Users with a more tailored experience. You can opt out of Google Analytics by visiting Google’s Opt-Out Browser Add-on website https://tools.google.com/dlpage/gaoptout.
Google Tag Manager. We use Google Tag Manager to manage tags we place on our Sites for tracking and analytics purposes. These tags include Web Beacons and tracking pixels. To learn more about Google Tag Manager’s privacy policies, visit https://policies.google.com/privacy?hl=en.
Google Optimize. We use Google Optimize to perform A/B testing (presenting different versions of the same resource, such as a webpage, to see which version performs better). Google Optimize integrates with Google Analytics to present us with User Data regarding Users’ experience with the different versions of the resource. You can learn more about Google Optimize’s privacy policies at https://policies.google.com/privacy?hl=en.
PayPal. We utilize PayPal to process payment transactions. When you make a purchase, by selecting PayPal, you might be required to provide Personal Data together with your payment Personal Data (including but not limited to, your credit card number), or you might choose to connect with your PayPal account. PayPal collects the Personal Data you enter and stores that Personal Data on its website. To learn more about PayPal’s policies, you can visit its website https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
Pinterest. We use Pinterest to measure the effectiveness of our content and advertising campaigns. Pinterest may use cookies, pixels, or similar technologies to collect data about User interactions with our website and with Pinterest ads or content. This information helps us better understand our audience and provide Users with a more relevant and tailored experience. You can learn more about how Pinterest collects and uses data, as well as how to manage your preferences, by visiting https://policy.pinterest.com/privacy-policy.
Salesforce. We use Salesforce as our customer relationship management (CRM) software. We use Salesforce to store Data regarding a User’s donation or purchase such as name, contact Personal Data, and donation/purchase history. We also store customer support interaction in Salesforce. You can learn more about Salesforce’s privacy policies at https://www.salesforce.com/company/privacy/.
SendGrid. We use SendGrid’s e-mail services to send transaction e-mails to Users, for example, to notify a User that the credit card he or she uses for recurring donations is about to expire. We track how Users open these e-mails and what links they click so that we can better serve customers with services and Personal Data that they find relevant. You can learn more about SendGrid’s privacy policies at https://sendgrid.com/policies/privacy/
Shopify. We use Shopify to execute software used in making purchases and to store purchasing data. Our CRM may also pull data from Shopify to store in our CRM database. When you purchase a product or service from us, you provide certain Personal Data so Shopify can process your purchase. This may include your name, contact Personal Data , billing Personal Data , or payment Personal Data. To learn more about Shopify’s privacy policies,
visit https://www.shopify.com/legal/privacy.
Spotify. We use Spotify to share content and measure the effectiveness of our campaigns. Spotify may use cookies, pixels, or similar technologies to collect data about User interactions with our website and Spotify ads or content. This information helps us understand engagement and provide Users with a more relevant and tailored experience. You can learn more about how Spotify collects and uses data, as well as how to manage your preferences, by visiting https://www.spotify.com/legal/privacy-policy
Stripe. We utilize Stripe to process payment transactions. When you make a purchase, by selecting Stripe, you will be required to provide Personal Data, together with your payment Personal Data (including but not limited to, your credit card number). Stripe collects the Personal Data you enter and stores that Personal Data on its servers. To learn more about Stripe’s policies, you can visit its website https://stripe.com/us/legal/.
TikTok. We use TikTok to measure and improve the effectiveness of our content and advertising campaigns. TikTok may use cookies, pixels, or similar technologies to collect data about User interactions with our website and with TikTok ads or content. This information helps us understand engagement, optimize performance, and provide Users with a more relevant experience. You can learn more about how TikTok collects and uses data, as well as how to manage your preferences, by visiting https://www.tiktok.com/legal/page/us/privacy-policy/en
WordPress. We use WordPress to host our Sites. WordPress stores basic website traffic data, which means that WordPress may collect Log Data when you visit our Sites. You can learn more about WordPress’s privacy policy at its website, https://automattic.com/privacy/.
Personal Data security
We take reasonable steps online and offline to safeguard the Personal Data that you provide to us, including:
- hosting your Personal Data with enterprise-grade service providers that use Secure Sockets Layer (SSL) encrypted connections (HTTPS), secure multi-tiered firewalls, encryption, secure cloud-based environments, server authentication, and industry-standard firewalls;
- using password managing software to manage our passwords; and
- using two-factor authentication to access backend systems.
If you have any questions about security on our Sites, or if you become aware of any unauthorized use of an Account, loss of your Account credentials, or suspect a security breach or an incident with your Personal Data please notify our DPO immediately via [email protected] (if you are an European resident) or [email protected] (if you are a non-European resident). If our security system is breached, we will notify you of the breach to the extent required under applicable law.
Rights to Your Personal Data
You may rectify, complete, update or delete any obsolete, incorrect or incomplete Personal Data that Personal Data you provided when you set up your Account through our Sites through your Account settings. Under certain circumstances, for example when such Personal Data are no longer necessary for the purposes for which they were collected or when you have withdrawn your consent and there is no other legal basis for the processing, you may also request the deletion of this Personal Data by sending an e-mail to our DPO via [email protected] (if you are an European resident) or [email protected] (if you are a non-European resident). However, this is not always possible due to legal requirements and exceptions may apply. Please note that if you request erasure of your Account, we, in complying with your request, may also delete any and all Data that has been submitted to us through our Sites or anonymize it.
If you access our Sites from certain jurisdictions, such as the EEA (in other words, if you are an European resident), you may have additional rights and options regarding the processing of your Personal Data, in particular:
Right to be informed: you have the right to be informed, no later than when your data are collected, about the processing we carry out, your rights relating thereto and the exercise of these rights. This being the case, we have drawn up this Notice.
- Right of access: you have the right to access and view the Personal Data concerning you and to obtain a copy of Personal Data as it exists in our records by logging into the Account you have created for yourself on the Sites or e-mailing us [email protected]. You may also obtain an answer to any questions you may have concerning the processing of your Personal Data (purposes of processing, recipients of data, retention period, etc.).
- Right to limit/restrict processing: In certain circumstances, you have the right to request the limitation of the processing of your Personal Data. We may thus temporarily and/or partially stop the processing being carried out. You may definitively stop a specific processing operation, or all processing operations carried out by us on your Personal Data by exercising your right to object.
- Right to object to certain types of processing: In addition, under certain circumstances, for example, due to his or her particular situation, for direct marketing uses, or for scientific or historical research, you have the right to object to the processing of your Personal Data. This right cannot be exercised when the processing is necessary for the fulfilment of legal obligations.
- Right to the portability of your Data: you also have the right to receive a copy of the Personal Data that you have provided to us in a commonly-used format and/or transfer their Personal Data directly to another data controller (where technically feasible).
- Right to withdraw your consent: if you have given your consent to our processing of your Personal Data for certain purposes, you have the right to withdraw consent to such use at any time and without justification by contacting us via the contact details indicated below in this Notice.
- Right to lodge a complaint with a Data Protection Authority: If you are not satisfied with how we manage your Personal Data or handle your data subject’s rights requests, you have the right to file a complaint with a Data Protection Authority. A list of National Data Protection Authorities can be found here.
Personal Data retention
We retain the Personal Data we receive as described in this Privacy notice for as long as you use our Sites or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Given that the need to retain data depends on the type of data and the purpose of the processing, retention periods may vary considerably. The criteria we go by to determine retention periods of your Personal Data are:
- How long do we need the data to provide the service requested?
- Do we have established and announced a specific retention period?
- Do we have obtained consent to extend the retention period?
- Are we subject to a legal, contractual or other obligation?
As soon as we no longer need your data and are no longer legally required to retain them, we permanently delete them or, if this is not possible, we anonymise them in our system and retain them for a reasonable amount of time for archival purposes.
Personal Data processed when subscribing to the newsletter will be retained until you choose to withdraw your consent to receive future newsletters from us. Please note that this withdrawal will have effect only for the future.
Links to Third Party Sites
The Sites may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. Such links do not constitute an endorsement by us of those other websites, their content or services, or the persons or entities associated with those websites. This Privacy notice does not apply to third-party websites. We have no control over, and assume no responsibility for, the content, privacy notices, or practices of any third-party sites or services. We encourage you to read the Privacy notices and terms of all third-party websites or services that you may visit.
Children’s Privacy
We do not sell products or services to anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”) and the General Data Protection Regulation (‘GDPR’), we will never knowingly request or solicit Personal Data from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Data without the requisite and verifiable parental consent, we will delete that Personal Data from our database as quickly as possible. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Sites.
California residents: Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such Personal Data , by emailing a request to [email protected].
Changes in the Privacy Notice
We reserve the right to modify and update this Privacy notice at any time by posting an amended version of the Notice on our Sites. Please refer to this Privacy notice regularly. If at any time we decide to use Personal Data in a manner different from that stated at the time it was collected, we will adapt this Privacy notice accordingly.
How to Contact Us
Because protecting your privacy and Personal Data is important to us, you may always submit concerns or questions regarding our Privacy notice, the processing of your Personal Data or the exercise of your Rights under privacy laws. We will attempt to respond to all reasonable concerns and inquiries expeditiously.
For European citizens or residents, please contact our European Data Protection Officer at:
By e-mail: [email protected]
By post:
BDO Brussels (Airport)
The Corporate Village
Da Vincilaan 9 – Box E.6
1930 Zaventem – BELGIUM
For non-European citizens or residents, please contact our US Data Protection Officer at:
By e-mail: [email protected]
By post:
Search for Common Ground
1730 Rhode Island Ave, Suite 1101
Washington, DC 22036,
USA