Privacy policy

The RSH Privacy Policy

Terre des hommes Foundation (Tdh) is the data controller and takes your privacy seriously and understands the importance of maintaining the confidentiality of your personal data and other information stored about you.

Tdh is committed, in the course of its activities and in compliance with applicable data protection laws, to ensure the confidentiality, integrity and availability of your personal data, as well as to respect your privacy.

The commitments described in this privacy policy (the “Privacy Policy”) fulfil the values, the principles of action and behaviour of Tdh and are established in compliance with applicable UK and European laws.

This Privacy Policy has been drafted in English and has been translated in other languages. In the event of any discrepancy between the English and the translated texts, the English text shall prevail and be used to solve doubts of interpretation.

Date of issue of the latest version of this Privacy Policy: [05/2020]

WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy applies to Tdh's processing of your personal data when you visit and use the website safeguardingsupporthub.org (the RSH) and any services, digital content and functionality contained on it (together the "The RSH").

THE PERSONAL DATA WE COLLECT FROM YOU

Tdh collects and processes personal data in respect of your use of and interactions with the RSH in order to provide you with a service, to respond to you and to publish and share information plus documents related to safeguarding in international development. “Personal data” means any information that may be linked directly or indirectly to you as an individual. The types of Personal Data we may collect and process can be summarised as follows:

  1. Identity Data includes first name, last name.
  2. Contact Data includes email address, relevant organisation
  3. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access The RSH.
  1. Profile Data includes your username and password, language.
  2. Usage Data includes information about how you use The RSH.
  3. Communications Data includes your preferences in receiving newsletters from us.
  4. Cookie and Device Data. Details can be found in Section 10.
  5. Other. Other information you may provide to us, for example photographs.

HOW WE COLLECT YOUR PERSONAL DATA

We collect your personal data in a number of ways as described below.

Information you give to us directly:

We collect information on you where you:

  1. register an account with us on The RSH or log in and make changes to your online account
  2. register to receive newsletters from us; and
  3. contact us (including over the phone, or via email, post, or live chat).

Personal data we collect automatically:

Tdh also automatically receives and records non-sensitive information on its technical infrastructure logs about your computer when you visit The RSH, regardless of whether you have registered for an account or not by just browsing our servers.  Tdh may collect, including but not limited to, your Web browser software, your internet protocol (IP) address which identifies Your computer, THE RSH's cookies, the referring website and the page you requested. RSH may also collect information about your location, and your online activity on the The RSH. Please refer to Section 10 for more details in relation to our use of cookies.

HOW DO WE USE YOUR PERSONAL DATA

The personal data we hold on you will be used in a number of ways depending on The RSH as explained below. Under data protection laws we have to have a lawful basis for processing your personal data. We have indicated the lawful basis we rely on below in the headings.

Where we rely on legitimate interest as this lawful basis, our legitimate interest is necessary for promoting our business, improving the services we offer to you and your experience when you interact with us, and ensuring effective operational management and internal administration of our business and the exercise of our rights.

To fulfil contracts

If you enter into a contract with us by opening an account on the RSH we need to process personal data in order to fulfil the contract by providing the services and corresponding in relation to the same. If you do not provide the information to us, we may not be able to fulfil the contract and provide the services to you.

Where we have your consent

We ask for your consent to send you newsletters with updated information, such as upcoming events, latest news, most relevant resources etc. You can choose to unsubscribe at any time as explained in ‘your rights’ below. In some limited circumstances, we do not need to obtain your consent for marketing as explained in the legitimate interest section below.

Where we have a legitimate interest

We may process your personal data where it is necessary for our legitimate interests as a business in the following situations:

  • To respond to any enquiries, information requests or complaints you make to us or that are made about you.
  • To inform you of upcoming events, promotions and community initiatives and communicate with you about these, where you have shown an interest.
  • To contact you for your views and feedback on our activities.
  • To assist with internal record keeping.
  • To provide you with, and maintain the quality of, our website and to analyse the use of our website in order to help guide improvements.
  • Profiling to enable better service and personalisation as explained in more detail below.

Where we rely on legitimate interest as a ground for processing your personal data, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the personal data contained in these balancing tests on request and can find out more by contacting us using the details below.

We may also use aggregate anonymised information in order to help us develop our services and may provide such information to third parties. This information cannot identify you. 

PERSONAL DATA SHARING AND DISCLOSURE

We may share your personal data with the parties set out below for the purposes set out above.

  • With other external third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, technology providers and hosting companies; analytics companies. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
  • With external third-party data services; who help up to segment and understand our audience by providing additional information.
  • With external third parties, where Tdh finds that it is necessary, as determined in  Tdh’s sole discretion, to investigate, prevent or take action regarding illegal activities, suspected fraud, emergency situations involving potential threats to the physical safety of any persons, violations of contractual obligations or as otherwise required by law.
  • Certain third parties pursuant to court orders or warrants.
  • To third parties where you give us express permission to share your personal data in the course of your relationship with us from time to time.

Tdh will not sell, rent or transfer your personal data to third parties without your consent and for reasons other consistent with the purpose for which the data were originally collected or for other purposes authorized by law.

TRANSFER OF PERSONAL DATA

Our personal data is generally stored within the EEA but in limited circumstances may be transferred to suppliers located in the US.  Where Tdh transfers your personal data from within the EEA to a country outside the EEA, we ensure adequate security measures are in place to offer equivalent protection as your personal data would receive within the EEA and in compliance with applicable data protection law. We have in place EU Model Contractual Clauses as an adequate safeguard for transfers outside the EEA. For further details on how we safeguard your personal data transferred outside the EEA (including how to obtain a copy of such safeguards) contact us using the details set out in Section 15 below.

DATA RETENTION AND ARCHIVING

Personal data processed by Tdh will be retained only for as long as is necessary to fulfil the purposes outlined above in this Privacy Policy. This will generally (but not in all cases) be for the duration of time where you utilise our services, to comply with our legal obligations or to protect Tdh’s rights. When determining the relevant retention periods for your personal data, we will take into account factors including:

  • our contractual obligations and rights in relation to the personal data involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • statute of limitations under applicable law(s) which is the period during which contractual claims could be brought, being 10 years in Switzerland;
  • our legitimate interests where we have carried out balancing tests (see section on ‘How do we use your personal data’ above);
  • (potential) disputes; and
  • guidelines issued by relevant data protection authorities.

YOUR RIGHTS

By law, you have a number of rights (subject to certain conditions) when it comes to your personal data. Further information and

advice about your rights can be obtained from the data protection regulator in your country.

Rights

What does this mean?

Your right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential offers or opportunities). Unsubscribing from newsletters and e-mail marketing communications can most easily be done by clicking on the unsubscribe link at the bottom of any e-mail newsletter we have sent to you or, alternatively, by modifying your account settings and preferences.

Your right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.

Your right to Access your personal data

You have the right to obtain access to your personal data (if the RSH is processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you are aware and can check that we are using your personal data in accordance with data protection law.

Your right to Update and Rectification

You are entitled to have your personal data corrected if it is inaccurate or incomplete.

You are generally able to review, correct or update your personal data at any time by accessing your account on The RSH where it has been created. However, you may choose to send us a written request to do so on your behalf at any time.

The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for The RSH to keep using it. This is not a general right to erasure, there are exceptions.

 You are generally able to delete your personal data at any time by accessing your account on The RSH where it has was created. However, you may choose to send us a written request to do so on your behalf at any time.

Your right to restrict processing

You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, the RSH can still store your personal data, but will not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.

Your right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services.

Your right to lodge a complaint

You have the right to lodge a complaint about the way the RSH handles or processes your personal data with your national data protection regulator by contacting the applicable data protection regulator directly.

 

Your right to withdraw consent

 

If you have given The RSH your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

You can exercise any of these rights by contacting our service provider Terre des Hommes in writing (including via email or regular mail) on the details below. Please note that we may require to receive a proof of your identity before we can respond to your request.

 

Email: [email protected]     

Mail:     

Terre des hommes, Regional Office Budapest

Data Protection - Data Subject Request
1027 Budapest Bem rakpart 50
Hungary

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Tdh may refuse, restrict or defer the provision of information where Tdh has the right to do so under current data protection legislation.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know

DATA SECURITY

We want you to feel confident about using The RSH. Therefore, Tdh has appointed a dedicated experienced service provider, Terre des Hommes, and defined and implemented with it the reasonable technical and organizational measures necessary to maintain the security of personal data, according to the nature of the personal data processed and the circumstances of the processing, with the objective of avoiding (in the realm of the possible and having regard to the state of the art) non-authorised processing or access, alteration or loss (to ensure confidentiality, integrity and availability respectively).

Tdh uses industry-standard SSL encryption to protect data transmissions. If You communicate with us otherwise than via The RSH (e.g. by e-mail), You should, however, note that the secrecy of Internet is uncertain. By sending sensitive or confidential e-mail messages or information which are not encrypted, you accept the risk of such uncertainty and possible lack of confidentiality over the Internet.

Identity theft and the practice currently known as “phishing” are of great concern to the RSH. Safeguarding information to help protect You from identity theft is a great concern. The RSH do not and will not, at any time, request your credit card information, your account ID, login password or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

 

COOKIES

Cookies are text files that are placed on your computer and may be used to store your information. The RSH use cookies to provide you with content specific to your interests and track your use of The RSH. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the The RSH may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy here.

 

CHILDREN'S PRIVACY

The protection of personal data of children and adolescents is of particular concern to The RSH. The RSH and its content are not directed at children under the age of thirteen (13). The RSH recommends that parents discuss the use of the Internet and the provision of personal data on websites with their children before allowing minors under thirteen (13) to access the The RSH.

The RSH will not knowingly collect personal data from or about children under thirteen (13. If The RSH becomes aware that a minor under eighteen (18) has registered for an account on the The RSH, their access as a user will immediately be denied and their account deleted as quickly as possible (including all personal data associated with that account

If you believe that The RSH might have any personal data from or about a child under thirteen (13), please notify our appointed data processor Terre des Hommes at the following:

Email: [email protected]     

Mail:     

Terre des hommes, local office in Hungary
Data Protection - Data Subject Request
1027 Budapest Bem rakpart 50
Hungary

LINKS TO OTHER SITES

If any part of The RSH link to other websites, those websites do not operate under this Privacy Policy. If you choose to visit an advertiser or click on another third party link, you will be directed to that third party’s website. We do not exercise control over third party websites and therefore recommend you examine the privacy statements posted on these other websites to understand their procedures for collecting, using and disclosing personal data.

 

CHANGES TO THIS PRIVACY POLICY

The Privacy Policy is available at any time through The RSH and may be amended from time to time. We shall place an updated version on the applicable page of The RSH. The applicable page may also provide notices of changes to this Privacy Policy or other matters by displaying notices or links to notices to you generally on or within The RSH.

You are responsible for regularly reviewing this Privacy Policy. The RSH reserves the right to change this Privacy Policy at any time without prior notice to you. We will however notify you where we have made significant changes and where we have a relationship with you.

 

CONTACT US 

If you have any questions about this Privacy Policy, please contact our appointed data processor on the details below. If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the data protection regulator in your country.

Email: [email protected]     

Mail:     

Terre des hommes, local office in Hungary
Data Protection - Data Subject Request
1027 Budapest Bem rakpart 50
Hungary