Date Updated: April 1, 2019

Never Forget Elephant Foundation’s Privacy Policy

Welcome to Never Forget Elephant Foundation! Never Forget Elephant Foundation’s (“NFEF”, “we”, or “us”) website (the “Site”) provides a web portal through which individuals (“you”) can donate to NFEF for NFEF’s charitable purposes, view information about NFEF’s activities produced by NFEF, or sign up for to visit with NFEF in the locations that NFEF serves (together, the “Services”). This Privacy Policy sets forth our policy with respect to information that is collected from visitors to the Site and users of Services. Under applicable law, NFEF is the “data controller” of personal data collected through the Services.

Information We Collect

When you interact with us through the Services, we may collect information from you, as further described below:

Information You Provide: We collect information from you when you voluntarily provide such information, such as when you register for access to the Services or use certain Services. Information we collect may include but not be limited to username, email address, and any messages, images, transient VOIP data (to enable communication delivery only) or other content you send via the chat feature.

Other Information:

1.     Data We Collect Automatically: When you interact with us through the Services, we receive and store certain information such as an IP address, device ID, and your activities within the Services. We may store such information or such information may be included in databases owned and maintained by NFEF affiliates, agents, or service providers. The Services may use such information and pool it with other information in an anonymized or pseudonymized way to track, for example, the total number of visitors to our Site, the number of messages users have sent, as well as the sites which refer visitors to the Site.

 2.     Aggregated Information: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate and anonymized basis, and we may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

3.     Info through other Services: You may give us permission to collect your information in other services. 

4.     Third-Party Tools:We may use third-party web site analytic tools such as Google Analytics on our website that employ cookies to collect certain information concerning your use of our Services. 

Processing Location and Data Protection Officer

NFEF is based in the United States. No matter where you are located, you consent to the processing and transferring of your information in and to the U.S. and other countries. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live. We have appointed a Data Protection Officer in accordance with Article 37 of the General Data Protection Regulation. All inquiries associated with these policies can be directed to the Data Protection Officer at info@neverforgetef.org.

Our Use of Your Information

We use the information you provide in a manner that is consistent with this Privacy Policy. If you provide information for a certain reason, we may use the information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem. Also, if you provide information in order to obtain access to the Services, we will use your information to provide you with access to such services and to monitor your use of such services. NFEF may also use your information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. NFEF will not use this information to contact you unless you "opt-in" to receive future marketing communications. In addition, if at any time after you’ve “opted in” and you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact the Data Protection Officer.

Our Legal Bases for the Handling of Your Personal Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:

1.     To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them. For example, we handle personal data on this basis to create your account and provide our Services.

2.     Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes:

a.     Providing a safe and enjoyable user experience;

b.     Customer service;

c.     Protecting our users, personnel, and property;

d.     Processing job applications;

e.     Managing legal issues.

3.     Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

4.     To protect the vital interests of the individual or others: For example, we may collect or share personal data to help resolve an urgent medical situation.

5.     Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.

Our Disclosure of Your Information

NFEF is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties, as set forth below:

1.     Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution or similar event, your information may be part of the transferred assets.

2.     Consent: We may transfer your information with your consent.

3.     Agents, Consultants, Contractors, Service Providers, and Other Third Parties: Like many businesses, we sometimes hire other companies or individuals to perform certain business-related functions. These persons will be bound by contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose it to them. 

a.       We use third-party data processor Stripe to process your payment information. Information about how Stripe uses your data when you use the Site can be found at: https://stripe.com/US/privacy.

b.       We use third party data processor Google Analytics and Google Forms to process your data and book your information for use of the NFEF Services respectively. Information about how Google uses your data when you use our Site can be found at: https://policies.google.com/privacy?hl=en.

c.      We use third party provider MailChimp for our automated newsletters. Information about how MailChimp uses your data when you use our Site can be found at: https://mailchimp.com/legal/privacy/.

d.       We use third-party data processor Donorbox to process your donor information. Information about how Donorbox uses your data when you use the Site can be found at: https://donorbox.org/privacy.

e.      We use third party provider Squarespace for our website provider. Information about how Squarespace uses your data when you use our Site can be found at: https://www.squarespace.com/privacy.

 6.     Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of NFEF or Related Organizations, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

7.     Aggregated or Non-Identifiable Data: We may also share aggregated or non-personally identifiable information with our partners or others for business purposes.

Unsolicited Information

You may provide us with ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children

Our Services are for users age 16 and over and we do not knowingly collect personal information from children under the age of 16. If you are a parent or guardian of a child under the age of 16 and believe he or she has disclosed personal information to us please contact the Data Protection Officer. For residents of the EEA, where processing of personal information is based on consent, NFEF will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.

Links to Other Web Sites

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by us (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Data Retention

We will retain personal data for a period 6 month before we dispose of such data. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps. 

Security

We take reasonable steps to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information via the Internet.

Your Data Rights and Choices

You can opt in to all cookie-related processing or subscribe to email updates by explicitly agreeing to this privacy policy or by contacting the Data Protection Officer. We believe that users should be treated equally no matter where they are, and so we are making the following options to control your data available to all users, regardless of their location.

1.     You have the right to access all personal data NFEF has about you.

a.     If you would like to submit a data access request, you can do so from by contacting the Data Protection Officer. We will then start the process and provide you a link to access the personal data that NFEF has on you within 30 days.

 2.     You have the right to correct, update, amend, or delete the personal data NFEF has about you.

a.     You can correct, update, amend, or delete personal data or request other modifications by emailing the Data Protection Officer with the words “Personal Data Request” in the subject or body of your message, along with an explanation of what data subject right you are seeking to exercise. For your protection, we may take steps to verify identity before responding to your request.

3.     You have the right to object to or restrict the manner in which NFEF processes my personal data?

a.     You have a right to ask us to stop using or limit our use of your personal data in certain circumstances—for example, if we have no lawful basis to keep using your data, or if you think your personal data is inaccurate. NFEF offers you the ability to restrict the processing of your data for specific uses. To exercise these abilities and rights, please email the Data Protection Officer.

4.     You have the right to transfer your personal data from NFEF to any other third-party data storage that you wish. 

a.     You can request a data transfer by emailing the Data Protection Officer who will transfer all requested data to you (or to whomever you request) in a structure, commonly used, and machine-readable format. 

The rights and options described above are subject to limitations and exceptions under applicable law. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Contacting Us

Please also feel free to contact us if you have any questions about this Privacy Policy or the information practices of the Services. You may contact us by emailing the Data Protection Officer at info@neverforgetef.org.