This privacy policy (the “Privacy Policy”) is intended to inform you of the policies and procedures of Asociación Mani Amiche O.N.G. D.M. (“Asociación”, “we”, or “us”) and its affiliates. We take the privacy and protection of your Personal Information (as defined below) very seriously. We may collect Personal Information from you in accordance with the terms of this Privacy Policy when you visit website operated by Asociación (the “Website”). We are committed to protecting the privacy of visitors to our site.
This Privacy Policy is intended to inform the general public and users about the types of data we collect and how we collect it, as well as how we use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Website. Generally, if we process data (defined below), we will ensure that there is a statutory basis for such processing, or we will obtain consent. Processing of Personal Information shall comply with all data protection regulations applicable to Asociación, including but not limited to General Data Protection Regulation (“GDPR”). For purposes of GDPR, Asociación is a Controller (as defined below). As discussed herein, you can contact us at any time to: request access to information that we have about you; correct any information we have about you; and/or delete information that we have about you. If you have additional questions about our data collection or storage, please contact us at info@maniamiche.org
Definitions
“Account” means an Asociación account.
“Anonymous Information” means information not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of individuals.
“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; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law
“ED Request” means a request for an equivalency determination.
“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Process” or “Processing” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated 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.
“Services” means the services we offer through the Website.
If you see an undefined term in this Privacy Policy, it has the same definition as in our Terms of Use or the terms used by the European legislature for the adoption of the GDPR.
General security
Asociación takes commercially reasonable physical, electronic, and managerial precautions to prevent the loss and misuse of Personal Information under our control. Web-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, you are free to transfer Personal Information to us via alternative means, e.g. by telephone.
Personal Information we collect from our grantmaker members
There are two general categories of information we collect. In both instances, we only collect and use your information to provide the Services (e.g., for fulfilling an ED request, for getting our newsletter, for informing you about educational programs, updates in the field, and updates to the Services).
- Information you give that is necessary for the Services (required; provided as necessity)
We require and collect the following Personal Information that you voluntarily submit to us when you use the Website and Services. This information is necessary for the performance of a contract in which the data subject is a party and to allow us to comply with our legal obligations under the contract and more generally. The following information is required because without it, we may not be able to provide you with all the requested services:
- Payment Information. We may require you to provide us with certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
- Communications with Asociación regarding the Services. When you communicate with Asociación to provide additional contacts, or other information needed to fulfill a payment processing, for example, we collect information about your communication (such as your email address) and any information you choose to provide in order to provide the Services.
If you wish to use the Website and Services, we require the aforementioned information; if you do not want to provide this information, you should not use the Website or Services.
- Information you to choose to give (optional; provided with consent)
- When you enter any information, including Personal Information, into any posting or comments within the Services, we will collect such information;
- When you respond to one of our surveys, we will collect any information contained in such survey responses; and
- When you leave us feedback or request support, we will collect any information that is contained in your feedback or support request (including your email address).
Personal Information we collect from Asociación
Information you to choose to give (optional; provided with consent)
- When you enter any information, including Personal Information, into any posting or comments within the Services, we will collect such information;
- When you respond to one of our surveys, we will collect any information contained in such survey responses; and
- When you leave us feedback or request support, we will collect any information that is contained in your feedback or support request (including your email address).
Information we collect via technology
When you access any part of our Website, our web server software automatically logs information provided by your network connection and web browser software, including the Internet Protocol (IP) address of your network connection and the type of web browser and operating system that you are using. Our web server may also log the URL of the file that you are requesting, the current date and time, and the URL of the last web page requested by your web browser.
We may utilize cookies on our Website to store your login information (if any) and your personal preferences for the Services. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them).
We may utilize Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to gather information relating to the usage of our website. The information generated by cookies (including IP addresses) is transmitted to and stored on Google servers. This information may then be analyzed and compiled into reports on website activity. Google may also transfer this information to third parties where required to do so by law, or where said third parties process the information on Google’s behalf. Google will not associate any data gathered from our Website with any other data held by Google.
You have the option of disabling or not accepting cookies by changing the preferences in your web browser and thus permanently deny the setting of cookies. If you deactivate the setting of cookies in your browser, it is possible that not all functions of our website(s) may be entirely used. For example, if you opt to disable cookies, you will still be able to access our Website, but you may not be able to use certain features of the website, including placing ED Requests.
We use Mailchimp as our marketing platform to send a monthly Newsletter. When you subscribe to the Newsletter you acknowledge that your information will be transferred to Mailchimp for processing. Learn more about Mailchimp’s privacy practices here (https://mailchimp.com/legal/).
Use of information we collect
In general, we use Personal Information you submit to us to provide the Services to you, respond to requests you make, improve the Services, and offer you additional information, opportunities, and functionality. We may also use your Personal Information to provide you with updates about the Services. Finally, we may rely on Personal Information in order to comply with our legal obligations. Personal Information is not used for any additional purposes, such as to profile those who access our Website. None of the Personal Information we collect will be shared with third parties without your express authorization.
- Providing and improving the Services
- Enable you to access and use the Website and the Services.
- Operate, protect, improve, and optimize the Services and experience, such as by performing analytics and conducting research.
- Provide customer service.
- Send you service or support messages, updates, security alerts, and account notifications.
- Send you promotional messages and other information that may be of interest to you based on your preferences (including information about Asociación or related programs).
If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we will not associate such feedback with your Personal Information. We will collect any information contained in such communication and will treat any Personal Information included in such communication in accordance with this Privacy Policy. We may create Anonymous Information records from Personal Information by excluding information that makes the Personal Information personally identifiable to you. We may use this Anonymous Information to learn more about how visitors use our Website, to analyze trends, to administer the site, to track visitor movement, and to gather general demographic information for reporting purposes.
We process this information given our legitimate interest in improving the Services and our users’ and members’ experience, and where it is necessary for the performance of the contract with you and/or a legal obligation. You can opt-out of receiving communications from us by following the unsubscribe instructions included in our marketing communications.
We process this information given our legitimate interest and legal obligation to protect the Website, to measure the adequate performance of our contract with you, and to comply with applicable laws. Asociación may process your information if it is necessary for legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Your choices regarding your Personal Information
Asociación regularly sends newsletters and promotional communications to (a) let you know about new features or changes to our Services, (b) offer you opportunities to participate in special promotions, events, and surveys, and (c) notify you about services offered by outside partner organizations. These emails will originate from Asociación or its affiliates. You may choose to opt-out from receiving such communications by following the unsubscribe instructions provided in the communication or by editing your communication preferences in your Account.
You may also occasionally receive administrative site and service announcement updates via email (such as, but not limited to, notice that we have changed the Services or the Privacy Policy) when we believe necessary. You may not opt-out from these announcements (which are not promotional in nature), as they contain important information about changes to our Services.
How to change your information
If you would like to change any of your Personal Information send a request to change, correct, or remove information to info@maniamiche.org
Links to outside website
This Privacy Policy applies solely to information collected through the Website. Our Website may contain links to outside website for your convenience, and such links do not signify our endorsement of such website or their contents. Asociación has no control over, does not review and is not responsible for the privacy practices of or content displayed on other website. We encourage our visitors to be aware when they leave our Website and to read the privacy policies of each and every third party website that collects information from you.
Regarding minors
The Website are not designed for minors under the age of 13. We do not intentionally gather Personal Information about visitors who are under the age of 13.
Your rights
You may exercise any of the rights described in this section by sending an email to info@maniamiche.org Please note that we may ask you to verify your identity before taking further action on your request.
- Rectification of inaccurate or incomplete information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
- Data access and portability.
In some jurisdictions, applicable law may entitle you to request copies of your Personal Information held by us. You may also be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
- Data retention and erasure
We generally retain your Personal Information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your Personal Information to provide the Services to you, you can request that we erase your personal information. Please note that if you request the erasure of your personal information:
- We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
- We may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, Asociación may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with us may continue to be publicly visible on the Website, even after you requested your information erasure.
- Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.
- Withdrawing consent and restriction of processing
Where you have expressly provided your consent to the processing of your Personal Information by Asociación you may withdraw your consent at any time by sending a communication to Asociación specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where (a) you contest the accuracy of your Personal Information; (b) the processing is unlawful and you oppose the erasure of your Personal Information; (c) we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (d) you have objected to the processing (see below) and pending the verification whether the legitimate grounds of Asociación override your own.
- Objection to processing
At any time, regardless of applicable law, you may object to us processing your Personal Information for direct marketing purposes. You may, at any time, ask Asociación to cease processing your data for these direct marketing purposes by sending an email to info@maniamiche.org
- Lodging Complaints.
With respect to GDPR, you have the right to submit complaints about the data processing activities carried out by Asociación before Office of the Inspector General for the Protection of Personal Data; for complaints unrelated to GDPR, nothing in this Privacy Policy is intended to limit your right to file a complaint in the appropriate jurisdiction.
EU Model Clauses
If your information is shared with corporate affiliates or third party companies or service providers outside the EEA, we have, prior to sharing your information with such corporate affiliate or third party company or service provider, established the necessary means to ensure an adequate level of data protection. This agreement may incorporate the basis of the EU Model Clauses (a set of clauses issued by the European Commission).
Privacy Policy updates
This Privacy Policy is subject to periodic occasional revision. If we make material changes to this Privacy Policy, we will notify you through this Website or, if you have provided your email address, by email. You agree that such amended Privacy Policy will be effective thirty (30) days after being posted or sent to you, and your continued access to the Website or use of the Services after such time shall constitute your acceptance of the amended Privacy Policy.
