We prioritize your privacy and are dedicated to safeguarding your personal information. We will solely utilize your email address or any other personal information for communication regarding The White Helmets Inc. work or relevant issues. Rest assured, we aim for a minimal impact on your inbox, striving for just one or two emails per month to keep you informed about developments and opportunities for action. You have the option to unsubscribe at any time.
More information about the White Helmets:
The White Helmets functions through four separate legal entities that share human resources and financial assets. These entities include the Canadian entity, also known as Les Casques Blancs, the Dutch entity, also known as Stichting White Helmets Foundation, the Turkish entity, also known as Beyaz Baretliler Derneği, and the US Charity, also known as The White Helmets Inc. Despite their independent legal identities, these entities share common goals and purposes. This privacy policy is issued on behalf of all four entities.
Attention: If you are under the age of 16, ensure that you have a guardian accompanying you when providing personal information online.
1. WHO WILL BE HOLDING YOUR PERSONAL INFORMATION?
1.1. The White Helmets Inc., Stichting White Helmets Foundation, Beyaz Baretliler Derneği, and Les Casques Blancs each function as an individual controller and collectively act as joint controllers, sharing responsibility for processing the personal information (referred to as "we," "us," or "our" in this privacy policy) you provide via this website or any other sources.
1.2. Any individual accessing our website can view information that you make publicly available on the site. While other visitors are bound by the website's terms and conditions, we cannot guarantee their compliance. Consequently, we advise against disclosing any personal information about yourself or others when making public contributions to the website.
1.3. We have designated a data privacy focal point tasked with overseeing inquiries related to this privacy policy; you can find the details in clause 11 of this Privacy Policy. For any questions regarding this privacy policy or requests to exercise your legal rights, please contact the data privacy focal point using the provided details at the bottom of this privacy policy.
1.4. Our website may contain links to third-party websites, plug-ins, and applications. Clicking on such links or enabling connections may result in third parties collecting or sharing data about you. We do not have control over these third-party websites and cannot be held responsible for their privacy statements. As you navigate away from our website, we recommend reviewing the privacy notice of each website you visit.
2. INFORMATION WE COLLECT
2.1. Personal Identifiable Information (PII) is defined as:
Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Further, PII is defined as information: (i) that directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or (ii) by which an agency intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors). Additionally, information permitting the physical or online contacting of a specific individual is the same as personally identifiable information. This information can be maintained in either paper, electronic or other media.
2.2 The personal information that we collect from you may include, but is not limited to, the following information about you:
2.2.1. Identity Data includes first name, last name, date of birth.
2.2.2. Contact Data includes billing address (where you are donating to us), email address, home address, telephone number, country of residence.
2.2.3. Financial Data includes bank account and payment card details (where you are donating to us)
2.2.4. Technological Data includes information about the way you use our website, so that we can improve the effectiveness of our campaign (see our cookie policy for more information). We do not track our users and visitors over time and across third party websites to provide targeted advertising. Consequently, we do not respond to Do Not Track (DNT) signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
2.2.5. Transaction Data includes details about payments to and from you and other details relating to donations you have made to us.
2.2.6. Profile Data includes your feedback, comments, survey response and donations.
2.3. We gather, utilize, and disclose Aggregated Data, such as statistical or demographic information, for various purposes. While Aggregated Data may originate from your personal details, it is not classified as personal information under the law, as it does not disclose your identity, either directly or indirectly. We assure you that if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.
2.4. We refrain from gathering any Special Categories of Personal Data concerning you, which encompasses information related to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, details about your health, and genetic and biometric data. Additionally, we do not collect information regarding criminal convictions and offenses.
3. HOW DO WE COLLECT INFORMATION?
3.1. We use different methods to collect data from and about you including through:
3.1.1. Direct interactions. You can share your personal information with us through direct interactions, whether by completing forms, corresponding with us via mail, phone, email, or any other means. This encompasses instances when you:
a) enquire about our activities, the website or us.
b) donate to us.
c) sign-up to receive updates on a campaign or an activity.
d) post comments or other content to the website.
e) contact us through the site or any other channel; or
f) Endorse a petition on the website.
3.1.2. Automated technologies or interactions: During your interaction with our website, we may automatically gather Technical Data concerning your equipment, browsing actions, and patterns through the use of cookies. You have the option to configure your browser settings to reject all or certain types of cookies, or to receive notifications when websites attempt to set or access cookies. It is important to be aware that disabling or refusing cookies may result in certain sections of our website becoming inaccessible or functioning improperly. For more information, please refer to our "Cookie Policy".
3.1.3. If it is legally required or stipulated by the terms of a contract, we hold with you to collect personal data, and you do not furnish the requested information upon request, it may impede our ability to fulfill the contract in place or under negotiation. For instance, this could affect our capacity to provide goods or services to you. Should such a situation arise, and we are compelled to cancel a product or service you have with us, we will notify you promptly.
4. HOW WE USE THIS INFORMATION WE COLLECT
4.1. We will utilize your personal information in accordance with applicable laws. Primarily, we will use your personal information in the following situations:
a) Facilitating your participation on our website.
b) Furnishing you with information you have specifically requested.
c) Displaying any comments you contribute to the website.
d) In the event of signing a petition or commenting while doing so, your first name, country, and comment may be visible on our activity stream (found on a petition page).
e) Providing information related to us or content we believe might interest you, including details about our events and activities.
f) Processing any donations you make to us.
g) Maintaining our organizational records.
h) Communicating with you via email regarding website matters, such as updates, developments, or modifications to our terms and conditions or privacy.
5. LEGAL BASIS FOR PROCESSING
5.1. To ensure that we process your personal information lawfully, our legal bases for collecting and using your personal information will include:
5.1.1. To fulfill our contractual obligations when you register as a donor and/or endorse a petition.
5.1.2. To adhere to our legal responsibilities, encompassing those specified in accounting, tax, and other relevant law.
5.1.3. To pursue our legitimate interests or those of a third party (such as our service providers, agents, or delegates) that do not supersede your interests or fundamental rights and freedoms. These interests include, but are not limited to: (i) managing business and operational risks; (ii) adhering to internal policies; (iii) sharing information among The White Helmets Inc. and other group members for administrative purposes; (iv) investigating, detecting, and preventing fraud and other crimes; (v) ensuring network and information security; (vi) procuring services from third parties that assist us in delivering our services to you and meeting our legal obligations; (vii) enhancing, refining, and informing you about our services and other products and services of potential interest to you; (xiii) nurturing the relationship and engaging with you in various capacities; (xiv) safeguarding our interests, including establishing, exercising, and defending legal rights and claims; and (xv) ensuring that our service providers, agents, and delegates can comply with their legal and regulatory obligations. When assessing whether legitimate interests can serve as a legal basis for the mentioned processing activities, a balancing test is conducted to determine whether the use of your personal information would be outweighed by your interests or fundamental rights and freedoms.
5.1.4. Under specific circumstances and in accordance with applicable laws, we may seek your consent. We will explicitly communicate this to you when collecting your personal data, and you will retain the right to withdraw your consent at any time. Typically, we depend on consent as a legal foundation for processing your personal information, particularly concerning the dispatch of direct marketing communications through email or text messages.
5.2. We will exclusively employ your personal information for the initially stated purposes unless we reasonably determine the necessity to use it for another purpose that aligns with the original one. If you seek clarification on how the processing for the new purpose aligns with the original one, please reach out to us at privacy@whitehelmets.org.
5.3. Should the necessity arise to utilize your personal information for a purpose unrelated to the initial intent, we will inform you and provide an explanation of the legal basis permitting such usage.
6. HOW WE SHARE YOUR INFORMATION
6.1. If you endorse a petition, share content, or post comments on our site, that information will be publicly accessible on the website.
6.2. We may engage carefully selected service providers, agents, and representatives to handle your information on our behalf, such as software providers for hosting the website. These third parties will only be authorized to utilize your information to fulfill their contractual obligations as processors, strictly following our instructions. They are not permitted to use the information for any other purpose. We will ensure that they implement appropriate technical and organizational security measures to effectively safeguard your personal information, with our continued responsibility for such data.
6.3. Only with your explicit consent, we may share your contact data with third-party organizations that we support in their charitable endeavors.
6.4. In extraordinary circumstances, we may disclose your information when legally obligated to do so.
6.5. International Transfers: The White Helmets Inc. may share your personal information with our campaign counterparts in the Netherlands, Canada, Turkiye, or other countries. This involves the transfer of your personal information outside the US. To safeguard your personal data, we require all our campaign counterparts to adhere to the same data processing rules.
7. HOW WE PROTECT PERSONAL INFORMATION
7.1. We employ suitable security measures to safeguard your personal information, aiming to prevent accidental loss, unauthorized use or access, alteration, or disclosure. Furthermore, we restrict access to your personal information to individuals, including employees, agents, service providers, contractors, and other relevant third parties, who have a legitimate business need to access such data.
7.2. We have established procedures to address suspected breaches of personal data and will inform you and any relevant regulatory authorities of a breach when legally obligated to do so.
8. CHANGES TO YOUR DETAILS OR THIS POLICY
8.1. We reserve the right to periodically revise or update this privacy policy to account for changes in our activities or other reasons. In such cases, we will post a notice of the changes on our website, and when deemed appropriate, we will notify you via email. We encourage you to review this policy each time you contemplate providing personal information.
8.2. Maintaining accurate and current personal information about you is crucial. If there are changes to your personal details, please assist us in keeping your information up to date by notifying us at the following email address: privacy@whitehelmets.org.
9. DATA RETENTION
9.1. We will retain your personal information only for the duration necessary to fulfill the purpose for which it was collected, which includes meeting any legal, accounting, or reporting obligations. In situations involving a complaint or if there is a reasonable anticipation of litigation concerning our relationship with you, we may retain your personal data for an extended period.
9.2. In determining the appropriate retention period for your personal information, we take into account factors such as the quantity, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for processing your information, the feasibility of achieving those purposes through alternative means, and compliance with relevant legal, regulatory, tax, accounting, or other requirements.
10. YOUR LEGAL RIGHTS
10.1. You have the following rights:
10.1.1. Request access to your personal information. This allows you to receive a copy of the personal information we hold about you and verify its lawful processing.
10.1.2. Request correction of your personal information. You can request correction of any incomplete or inaccurate information we hold about you, though we may need to verify the accuracy of the new data provided.
10.1.3. Request erasure of your personal information. You can ask us to delete or remove personal information where there is no valid reason for us to continue processing it. However, specific legal reasons may prevent us from fulfilling such requests, and we will notify you of these reasons, if applicable.
10.1.4. Object to the processing of your personal information when we rely on a legitimate interest (or that of a third party). You can object based on your specific situation if you believe it impacts your fundamental rights and freedoms. You also have the right to object when we process your personal information for direct marketing purposes. We may, in certain cases, demonstrate compelling legitimate grounds to process your information that override your rights and freedoms.
10.1.5. Request restriction of processing your personal information. You can ask us to suspend the processing of your personal information in scenarios such as establishing data accuracy, unlawful data use where erasure is not desired, the need to hold data for legal claims, or verifying overriding legitimate grounds for continued use when you have objected to our processing.
10.1.6. Request the transfer of your personal information to you or a third party. We will provide your personal information in a structured, commonly used, machine-readable format, but this right applies only to automated information for which you initially provided consent, or which was used to perform a contract with you.
10.1.7. Withdraw consent at any time where we rely on consent to process your personal information. Withdrawal does not affect the lawfulness of processing before consent withdrawal. However, certain products or services may not be available if consent is withdrawn, and we will inform you if this is the case.
10.2. There is no fee to access your personal data or exercise any of these rights. However, a reasonable fee may be charged for unfounded, repetitive, or excessive requests, or we may refuse to comply in these circumstances.
10.3. To confirm your identity and protect your right to access personal data, we may request specific information from you. We might also ask for additional details to expedite our response.
10.4. We aim to respond to all legitimate requests within one month. If a request is complex or multiple requests are made, it may take longer, and we will notify you and keep you informed.
11. CONTACT US
If you have any questions or comments, please let us know by contacting our team at privacy@whitehelmets.org.
We also have a data privacy focal point for questions in relation to your data:
Name: Mohamed Rashed
Address: 40 West 37th St., Suite 1000, New York, NY 10018-7311
Email Address: privacy@whitehelmets.org
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