Alternatives to Violence Project International, Inc. (“AVP International”, “we”, “us”) and our volunteers, contractors and employees are committed to collecting and treating Personal Data in accordance with the EU General Data Protection Regulation (“GDPR”), and specifically with Article 5 of the GDPR, providing you with transparency and choice in reference to the personal data you provide to us. AVP International is committed to providing reliable and accurate information to our website users and the AVP community using a variety of means, which are supported by a comprehensive privacy program.
This Privacy Statement (“Statement”) outlines how AVP International collects, uses, treats, stores, protects and discloses Personal Data collected from users of the AVP International websites ("Sites"). This Statement applies to all Personal Data processed by AVP International. Certain AVP International resources and services may have additional specific privacy notices that describe how we handle Personal Data for those resources and services. This Statement shall be reviewed at least annually.
This Statement describes the following general aspects of our Personal Data privacy policies:
- Data we collect;
- How we use Personal Data;
- How long we retain or store Personal Data;
- Sharing or disclosing Personal Data;
- How we protect Personal Data;
- Personal Data breaches;
- Privacy of children;
- Third party websites and social media features;
- Cookies and log files;
- Cross-border transfers of Personal Data;
- Your privacy rights;
- Changes to this Privacy Statement;
- Your acceptance of these terms, and
- Contacting us.
Data we collect
We may collect Personal Data from you in a variety of ways, including without limitation, when you visit our Sites, register on our Sites, subscribe to a newsletter or email group, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Sites. You may be invited or asked to provide, as appropriate, your name, email address, mailing address, phone number and a photographic image of yourself (“Personal Data”). You may visit and interact with our Sites anonymously, however some features may require you to log in. You can always refuse to provide Personal Data, acknowledging that it may prevent you from accessing certain parts of our Sites.
AVP International shall ensure the adequacy and relevance of the Personal Data, limiting this to what is necessary in relation to the purpose for which such data is treated.
We may collect non-identifier information about you whenever you interact with our Sites. Such information may include browser type, computer or device type, traffic data and other similar information relating to your usage of our websites.
We may combine the data we collect from you over time from our Sites, resources and services with data obtained from other public or AVP sources.
If you believe a third party has provided us with your Personal Data without your consent and you would like to request that it be removed from our database, please contact us at email@example.com.
How we use Personal Data
AVP International may use your Personal Data for the following purposes, on the basis of your consent and our legitimate interest in the effective delivery of our services and communications to you:
- To create and manage your Site account to access certain sections and services on the AVP International websites;
- To verify your identity and entitlement to our resources or services;
- To manage your subscriptions, including to subscribe you to a newsletter, email group or other lists to receive communications from AVP International;
- To provide you with technical and user support;
- To evaluate and improve the performance and quality of our resources, services and websites, and to tailor your user experience;
- To allow interoperability within our applications;
- To comply with our legal obligations;
With your consent, some of your Personal Data may appear in different places on our Sites. Such Personal Data may include your name, country of residence, photographic image, and AVP activity or interests. AVP International will not publish personal email or mailing addresses, or phone numbers.
Under Article 49 of the GDPR, organisations have a recognised legitimate interest in collecting and treating Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring network and information security. Network and information security mean the ability of a network or an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.
It is our compelling legitimate interest to protect our organisation and our Site users from cyber-threats, and therefore our interest may override your objection, rectification or erasure request.
AVP International will only treat or process Personal Data on the basis of consent, contract, legal obligation or legitimate interest. Where consent is the basis for treating Personal Data, evidence of opt-in or opt-out, accordingly, shall be stored with the Personal Data in question.
How long we retain or store your Personal Data
We will hold your Personal Data on our systems for: a) as long as necessary to maintain our ongoing relationship with you, or as needed to provide you with the resources, services or information to which you are entitled or can otherwise reasonably expect to receive from us; b) as long as necessary for the purpose for which we collected it or for which you provided it to us, and c) any retention period that is necessary to comply with our legal obligations and enforce our agreements.
We will delete or de-identify your Personal Data when it is no longer needed for its originally stated purposes or any additional compatible purpose for which AVP International may lawfully further treat such data.
Sharing or disclosing your Personal Data
AVP International will not sell, trade, rent or give away your Personal Data. We may disclose your Personal Data as described in this Statement within AVP International or on our websites. In certain instances, AVP International may be compelled to disclose your Personal Data to public authorities or as otherwise required by applicable law.
How we protect Personal Data
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your Personal Data, username, password, transaction information and data stored on our Sites.
We use network and information security technologies such as anti-virus and protection software, encryption and data loss prevention, and we monitor our systems to ensure they comply with our security policies.
All AVP International volunteers, contractors and employees receive awareness training on the importance of protecting your Personal Data, including the necessary knowledge and processes to protect the same as outlined in our Policies and Procedures Manual.
Personal Data breaches
AVP International takes reasonable measures to prevent Personal Data breaches. In the event of a breach, our actions will be consistent with our role in relation to the resources, services or processes affected by the breach. We will work together with the affected parties to minimise effects, make all notifications and disclosures as required or warranted, and take actions to prevent future breaches.
Privacy of children
Our websites are not directed to, nor do we knowingly collect data from, children under 13 years of age, except where explicitly described otherwise in the privacy notices relating to photographic images.
Third party websites and social media features
Our websites may contain links to other websites that are owned or operated by other organisations or third parties. AVP International is not responsible for the practices employed by websites linked to or from our Sites. We encourage you to review their privacy statements carefully, as they may differ from ours.
Cookies and log files
We gather certain data automatically and store it in log files. This data may include internet protocol (IP) addresses, browser type, referring/exit pages, date/time stamp, and/or clickstream data. We do this for statistical purposes to monitor website usage.
Cross-Border transfers of Personal Data
AVP International is a global organisation and as such we may process data in different countries. All such transfers of data will occur in compliance with data transfer requirements as set forth in the GDPR and other applicable laws. Where Personal Data originating from the European Economic Area is transferred to AVP International in countries that are not recognised by the European Commission as offering an adequate level of Personal Data protection, such transfers shall be covered by alternate appropriate safeguards.
Your privacy rights
Subject to applicable law, as an individual you may:
- Ask us to provide you with information regarding the Personal Data we process concerning you;
- Rectify, update or complement inaccurate or incomplete Personal Data concerning you;
- Delete or request the erasure of Personal Data concerning you;
- Withdraw any consent you may have given for us to treat Personal Data concerning you;
- File a privacy complaint with a supervisory authority if you are unhappy with the way we have treated your Personal Data or handled any privacy request that you have made of us.
AVP International has a legitimate interest in promoting our offerings and to optimise the delivery of communications to that effect to our audiences that are most likely to find them relevant. If at any time you would like to unsubscribe from receiving future emails, follow the unsubscribe instructions at the bottom of the email or write to firstname.lastname@example.org to be removed from any email list.
Where the exercise of any of the rights above is dependent on action by AVP International, we will take reasonable measures to ascertain your identity and the legitimacy of your request, and may ask you to disclose to us any information necessary for that purpose. We will respond to legitimate requests within one calendar month.
The AVP International Board of Trustees (Coordinating Committee) shall take responsibility for AVP International’s ongoing compliance with this Statement and associated policies.
Changes to this Privacy Statement
AVP International may revise or modify this Statement at any time. If we make any material changes, we will notify you by a notice posted on this website. We encourage you to periodically review this page for the latest information on our privacy practices.
Your acceptance of these terms
By using this Site, you signify your acceptance of this Statement and any modifications thereof. If you do not agree, please do not use our Sites. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
To exercise any of your rights, write to email@example.com.
If you have any questions or complaints about our use of your Personal Data, this Privacy Statement or AVP International’s privacy practices, please write to firstname.lastname@example.org.
Revised: January 2019
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