Privacy Policy

Effective Date May 19, 2020

 

1. Introduction and Overview

This Privacy Policy provides a comprehensive description of how Christian Engagement for Development, Inc. (“CED,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information. It applies to any online location that links to this Privacy Policy (the “Service”).

By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are a data subject in Europe, please see the additional disclosures at the end of this Privacy Policy.

 

2. Information Collection

A. Information You Provide

We collect information about you when you use the Service, including information you provide when you access our content, make a donation, or contact customer support. The categories of information we collect include:

  • Contact Data, including your first and last name, email address, postal address, and phone number.
  • Donation Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
  • Content, including content within any messages you send to us (such as feedback and questions to customer support).

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:

  • Service Use Data, including data about features you use, pages you visit, the time of day you browse, and your referring and exiting pages.
  • Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.
  • Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

We use tracking technologies to automatically collect information, including log files, which are files that record events that occur in connection with your use of the Service.

For further information on how we use tracking technologies for analytics, and your rights and choices regarding them, see the “Your Rights and Choices” and “Analytics” sections below.

C. Information from Other Sources

We also collect information from other sources. The categories of sources from which we collect information include:

  • Partners that help us provide humanitarian services.
  • Publicly-available sources, including data in the public domain.

 

3. Use of Information

We collect and use information for our legitimate interests and business purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, and for which we have collected and used information include:

  • Operating and managing our Service, including donations for those in need.
  • Performing services requested by you, such as responding to your comments, questions, and requests, and providing customer service.
  • Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
  • Preventing and addressing fraud, breach of policies or terms, and threats or harm.
  • Monitoring and analysing trends, usage, and activities.
  • Conducting research, including focus groups and surveys.
  • Improving the Service and other CED products and services.
  • Developing and sending advertising, direct marketing, and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
  • Fulfilling any other purpose at your direction.
  • With notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

 

4. Sharing of Information

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

  • Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services, such as DonorBox that processes donations for us, data analytics providers, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
  • Affiliates. We may share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
  • Partners. We share information with our partners in connection with offering humanitarian services.
  • Merger or Acquisition. We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
  • Facilitating Requests. We share information at your request or direction.
  • Consent. We share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

 

5. Other Parties

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

 

6. Your Rights and Choices

A. Do Not Track

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

B. Analytics

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Please note that if you opt out, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

C. E-mail Communications

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations. Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.

 

7. Children

The Service is intended for general audiences, and is not directed at children under 13 years old. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, contact us at info@ced-usa.org . We will remove the personal information in accordance with COPPA.

 

8. Data Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

 

9. International Transfer

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.

 

10. Changes to this Privacy Policy

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

 

11. Contact Us

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us at:

info@ced-usa.org

 

12. Additional Disclosures for Data Subjects in Europe

A. Roles

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). CED acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.

B. Lawful Basis for Processing

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, and partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.

C. Your Data Subject Rights

You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.

Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.