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PRIVACY POLICY.
A legal disclaimer
Automated Information: We also collect information, some of which may be Personal Information, through automated means when you visit our Website (“Automated Information”) such as:
the IP address of the device you use to connect to the internet (which may include information about your geographic location)
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The unique identifiers of your device
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Your browser characteristics
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Your device characteristics
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Your operating system
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Your language preferences
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The websites you visited before coming to our Website or through which you were referred to our Website
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Information on actions taken by you on our Website
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Dates and times of your visits to our Website
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The pages you accessed on our Website
Most web browsers automatically accept cookies. If you do not wish to have cookies on your system, you can set your browser to refuse them. Please review the specific instructions from your browser in order to do this. However, please note that not accepting cookies may make certain features of our Website unavailable or difficult to view or use.
Automated Information: We also collect information, some of which may be Personal Information, through automated means when you visit our Website (“Automated Information”) such as:
the IP address of the device you use to connect to the internet (which may include information about your geographic location)
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The unique identifiers of your device
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Your browser characteristics
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Your device characteristics
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Your operating system
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Your language preferences
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The websites you visited before coming to our Website or through which you were referred to our Website
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Information on actions taken by you on our Website
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Dates and times of your visits to our Website
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The pages you accessed on our Website
Most web browsers automatically accept cookies. If you do not wish to have cookies on your system, you can set your browser to refuse them. Please review the specific instructions from your browser in order to do this. However, please note that not accepting cookies may make certain features of our Website unavailable or difficult to view or use.
Information We Obtain from Third Parties: We may obtain Personal Information from third parties in a number of ways:
We may obtain Personal Information from third parties for marketing and business purposes. If we obtain Personal Information from third parties for any of these purposes, we will require that any third parties from whom we may obtain such Personal Information represent to us that they have acquired the Personal Information in compliance with all applicable laws and have the right to provide us such Personal Information for our marketing purposes.
We may collect Personal Information from publicly available sources.
III. How will Le Saints use your personal data?
Le Saints will use your Personal Information for the following purposes:
a. For administrative reasons, including:
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“Service administration,” which means that Le Saints may contact you for reasons related to administering any donations you have made, the completion of commercial or other transactions you have entered into with us, or the activity or online content you have signed up for;
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To confirm receipt of donations (unless you have asked us not to do this), and to say thank you and provide details of how your donation might be used;
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In relation to correspondence with us, whether by letter, email, text, social media, message board, or any other means, and to contact you about any content you provide;
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For internal recordkeeping to document your relationship history with us;
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To complete sales transactions you have entered into with us;
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To implement any instructions you give us with regard to withdrawing consent to send marketing information;
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To use IP addresses to identify the location of users, to block disruptive use, and to establish the number of visits from different countries.
b. For marketing and fundraising:
Sections III and IV describe what data may be used for marketing and fundraising purposes and under what circumstances.
c. Analysis: To analyze and improve the activities and content offered by the Le Saints Website to provide you with the most user-friendly navigation experience. We may also use and disclose Personal Information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
IV. Why do we hold and process personal data?
Le Saints may request from you, or you may volunteer to provide, your contact information, including your name, mailing address, phone number(s), social media handles, email address(es), and payment information. We hold and process supporters’ Personal Information for a number of reasons:
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To keep a record of donations made and actions taken by our supporters and our communications with them;
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To send supporters marketing information about our projects, fundraising activities, and appeals where we have their consent or are otherwise permitted to do so;
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To fulfill contractual obligations entered into with supporters;
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To support volunteers, such as during builds or fundraising events;
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To support community-based fundraising and campaigning;
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To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted;
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To manage supporters’ accounts and provide customer service;
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To offer contests, giveaways, or other promotions;
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To enforce the Website terms of service; and/or
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To perform other functions as described at the time Le Saints collects information.
Targeted Fundraising for U.S. and Canadian Residents:
We may use certain Personal Information (name, address, telephone number, or e-mail information, etc.) to contact you for the purpose of raising money for Le Saints, but any such communication will provide you with the opportunity to opt-out of receiving such future communications. If you do not elect to opt-out, we may exchange or rent your information with other organizations. If you re-engage with Le Saints without indicating your intent to opt-out, we will re-subscribe your email to ensure that you do not miss Le Saints updates. You are free to opt-out of fundraising solicitations, and your decision will have no impact on your ability to receive services from Le Saints or to volunteer with us.
If you did not opt-out from receiving fundraising communications, we may also analyze your Personal Information to create a record of your interests and preferences. This allows us to ensure communications are relevant and timely, to contact you in the most appropriate and relevant way, and in general to provide you with an improved user experience. It also helps us to understand the background of our supporters so that we can make appropriate requests for support, enabling us to raise funds and partner with families sooner and more cost-effectively.
If you did not opt-out from receiving fundraising communications, Le Saints may also share data from its U.S. and Canadian resident supporters with select third-party sponsors and service providers based on our assessment that the products or services may be of interest to these supporters or that the sponsor or provider can help Le Saints identify what services or appeals may be of interest to our supporters. We may also provide our U.S. and Canadian resident supporters with information about services from third parties. If you do not wish for your data to be used in this way, you may follow the instructions for modifying your consent (see below Section IX, “How to control what we send you or update your Personal Information”).
Other ways we use cookies to enable us to improve our services:
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remembering if you are logged in so you can move around the Website without having to log in again on each page (for example, if you are in checkout);
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measuring how many people are using each page of the Website and for how long so that we can try to improve the quality of our Website;
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enabling you to view content shared on social media or sharing sites, such as YouTube or Twitter.
If you reside in the United States or Canada, cookies may also be used for “re-targeting” in advertising campaigns so that third-party vendors can display advertising to you about Le Saints or other related entities as you use the internet.
How to manage and delete cookies:
If you wish to restrict or block the cookies set by the Le Saints Website, you can do this through your computer or device’s browser settings.
The Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies.
Please be aware that restricting cookies may affect the functionality of the Le Saints Website.
If you visit our Website as an anonymous visitor (e.g., you switch off cookies), Le Saints may still collect certain information from your browser, such as the IP address (which uniquely identifies a computer or other internet device).
VII. How we share your information inside and outside the Le Saints Network
If you reside in the U.S. or Canada, and unless you instruct us otherwise by opting out, Le Saints may share your personal data with organizations with which Le Saints partners, as well as other companies whose products and services may be of interest to you. In these cases, we may also provide you with information about services from third parties, unless you inform us that you do not want to receive this information.
Sharing of information within the Le Saints network:
We may share your Personal Information with a Le Saints National Organization, such as in connection with your participation in a Global Village build, or to enable a National Organization where you have expressed interest to update you about its own programs and campaigns or with local Le Saints Affiliates. Before we will share your Personal Information, Le Saints requires that the Le Saints National Organization or local Le Saints Affiliates receiving the data (the “Receiving Organization”) maintain security controls that will assure that your data is securely stored and accessible only by appropriately trained personnel. Unless you inform us that you do not consent, Receiving Organizations may in the future contact you about their own programs and activities.
Likewise, when you provide Personal Information to a National Organization in connection with your participation in a Global Village build or other international volunteer event that Le Saints sponsors or with a local Le Saints Affiliate, your personal data may be shared between (i) the Receiving Organization and any other Le Saints National Organization that hosts the volunteer build (the “Hosting Organization”) or the local Le Saints Affiliate, and (ii) the Receiving Organization and Le Saints. Unless you inform Le Saints or the Receiving Organization that you do not consent to marketing by the Hosting Organization or the local Le Saints Affiliate, the Hosting Organization or the local Le Saints Affiliate may also contact you about its own programs and activities in the future.
Le Saints’ service providers and business partners:
We may need to share your information with service providers, data brokers, third-party advertisers, payment processers, and/or government agencies who help deliver our mission, services, objectives, and fundraising activities. Le Saints may rent, sell, or exchange names, postal addresses, telephone numbers, and donation history to other organizations. If you do not want us to share your Personal Information with third parties who may use such information for their own independent purposes, you may call us at 1-800-xxx-xxxx, email us at privacymanager@lesaints.org, or write to us at: Data Privacy Manager; Le Saints International; 285 Peachtree Center Ave NE #2700, Atlanta, GA 30303.
Facebook and other Social Media Sites:
We may also use your email address and phone number to match to your Facebook or other social media account(s) in order to show you Le Saints content while you use those services. We only do this where you have consented to receiving marketing emails, either by opting in (where you reside in the European Economic Area) or by not opting out (where you reside in the United States and Canada).
In addition, we may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in Le Saints.
There are two ways to opt out of our sharing of your data. You can either update your consent preferences directly with us at Le Saints (see below Section IX, “How to control what we send you or update your Personal Information”) or via the social media sites.
Facebook: https://www.facebook.com/help/568137493302217
LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931
Twitter: https://business.twitter.com/en/help/troubleshooting/how-twitter-ads-work.html
Instagram: Adjust your Ad topic preferences on Instagram | Instagram Help Center
Please note the above third-party links are provided as a courtesy but are not under Le Saints' control and are subject to change at any time. Updating your preferences with Le Saints will not guarantee that you will never see Le Saints content on social media, since the social media site may select you based on other criteria.
Where legally required: We will also comply with legal requests where disclosure is required or permitted by law (for example, to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing).
VIII. How long will Le Saints keep your Personal Information?
We will hold your Personal Information on our contact lists only for as long as you continue to provide your consent. If you are a U.S. or Canadian resident, your ongoing consent is presumed unless you inform us that you wish to be removed from our contact list. (Instructions for doing this are set forth below in Section IX.) If you are not a U.S. or Canadian resident, your consent will be presumed to expire after 24 months, unless renewed consent is provided by you.
Beyond that, we will hold your information only for as long as necessary to comply with our legal and regulatory obligations—such as, for example, to provide documentation on funding sources in connection with a review or audit of our compliance with U.S.C. Sec. 501(c)(3).
If you request that we stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Legacy income is vital to the running of Le Saints. We may keep data (including Personal Information) you provide to us indefinitely to carry out legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyze the source of legacy income we receive.
IX. How to control what we send you, update your Personal Information, opt out of communications, delete your Personal Information from our records, request a copy of your Personal Information, or appeal a decision on how we handle your personal data
In certain countries and in certain states, you have specific rights regarding your Personal Information. This section describes your rights and explains how to exercise those rights.
Your data privacy rights and Colorado Privacy Statement
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Right to opt-out of sharing personal data: You are able to elect to direct us not to use your Personal Information. We share Personal Information (including name, contact information, and donation history) in the context of cooperatives managed by third-party vendors such as data brokers. The Personal Information provided is used by the third-party vendors to create a score or profile which may then be used to send solicitations on behalf of other organizations. These organizations will not have direct or continued access to your Personal Information unless you choose to provide it to them directly by responding to an appeal. We do not share health-related data in connection with these efforts.
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Right to opt-out of targeted advertising: You have the right to opt-out of targeted advertising through the processes outlined below for exercising any of these rights.
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Right to access: You can request and receive all Personal Information in a form that is concise, transparent, and easily intelligible and in an appropriate, commonly used electronic format, depending on the nature of the data. The right to access Personal Information may be limited by local law.
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Right to correction: You have the right to correct inaccuracies in your Personal Information.
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Right to deletion: You have the right to request that we delete any of your Personal Information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Please note that in cases of deletion, limited Personal Information will remain to document the request. The right to access Personal Information may be limited by local law.
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Right to portability: You have the right to request that your data be transferred to another entity in a format that we can transmit securely.
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Right of appeal: If you exercise one of your privacy rights and we are unable to process your request, we will endeavor to provide you with an explanation as to why the request was denied. The explanation will include information on how to appeal, including the relevant regulatory authorities, based on your state or country of residence. All requests for appeal will be reviewed by Le Saints' General Counsel in consultation with Le Saints' privacy and risk professionals.
Facebook: How to exercise your privacy rights or change the way we communicate with you:
Update your contact preferences:
For postal mail, visit le saints.com/preferences.
For email newsletters, visit le saints.com/email/manage.
You can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from Le Saints.
Contact us:
Email us at privacymanager@lesaints.org
Call us at (800) LE SAINTS — (800) xxx-xxxx
Or write to us at: Data Privacy Manager; Le Saints; 285 Peachtree Center Ave NE #2700, Atlanta, GA 30303 (to amend your preferences for any communication channel)
For your protection, we will use commercially reasonable efforts to verify your identity when you are exercising your right to have personal data corrected or deleted or to receive a copy of your personal data before implementing your request. If you are submitting a request on behalf of someone else, we may ask for additional verification, such as written documentation or other proof of authority. We will try to comply with your request as soon as reasonably practicable, consistent with applicable law.
For California Residents:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make a request, please contact us by any method detailed above. We will respond to your request consistent with applicable law.
For Colorado Residents:
If you have concerns about the appeal of any action related to your personal data, you have the ability to contact the Colorado Attorney General at https://complaints.coag.gov/s/contact-us or Office of the Attorney General Department of Law, Ralph L. Carr Judicial Building, 1300 Broadway, 10th Floor, Denver, Colorado, 80203. Please refer to the Colorado Privacy Statement.
Timing of implementation:
In responding to requests not to receive marketing information, we will take all reasonable steps to remove you from all Le Saints marketing lists. If you are a resident of the European Economic Area and your country has adopted the provisions of the GDPR, we are committed to meeting the following service levels:
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Email: 48 hours from receipt of email
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SMS: 48 hours from receipt of SMS
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Mail: six to eight weeks from receipt of ‘do not mail’ request. This period is longer than for other channels due to the production times for mailing or telephone campaigns.
If you have already been selected for inclusion in a Le Saints marketing campaign at the time you requested to not receive such information, we may be unable to remove you from that campaign within these time periods.
If you are a resident of the European Economic Area and your country has adopted the provisions of the GDPR, you have the right to request a copy of the Personal Information we hold about you, to have any inaccuracies corrected, and to have any Personal Information deleted from our systems (a “Subject Access Request” or “SAR”). In line with standard guidelines for these requests, we will require you to prove your identity with two pieces of approved identification. We will respond to such requests within 30 days of receipt.
Please address SARs, or questions or complaints about this Privacy Policy, to: Data Privacy Manager, Le Saints, 285 Peachtree Center Ave NE #2700, Atlanta, GA 30303.
X. How Le Saints keeps your data safe
We ensure that there are appropriate technical controls in place to protect your personal details and keep them secure. For example, our online forms that ask for Personal Information are stored on networks that are password-protected and routinely monitored. Laptops are not used to store sensitive Personal Information unless they are both password-protected and encrypted. All Sensitive Personal Information is stored on a secure database, to which only a limited number of relevant personnel have access. It is deleted when no longer needed by us and is never shared with third parties, except as expressly set forth in Sections III and IV.
Within Le Saints, we undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers, and contractors. Where we share your personal data with a Le Saints National Organization or Affiliate, the National Organization or Affiliate is required to take comparable steps to assure that your information is securely stored and accessed only by appropriately trained personnel.
We use external companies to collect or process Personal Information on our behalf. We do comprehensive checks on these companies before we work with them, and in our legal agreements, we clearly set out our requirements regarding how they manage the Personal Information to which they have access. We have a robust partner-monitoring framework to ensure these contractual obligations are met.
XI. Changes to Le Saints’ Privacy Policy
This Privacy Policy was last updated as of the date written above. It may be updated from time to time, so you may wish to check it each time you submit Personal Information to Le Saints. If you do not agree to these changes in this update, please review the instructions in Section IX to update your preferences and discontinue use of the Website. If material changes are made to the Privacy Policy, we will notify you by placing a prominent notice on the Website.
XII. General Data Protection Regulation (GDPR) for Citizens of the UK and European Union
We thank you for your intention to donate to Le Saints. Before you donate, we want to inform you according to Art. 13 General Data Protection Regulation (GDPR) and the applicable data protection rules about how we process your personal data.
Contact Details – Data Controller
Le Saints is committed to ensuring the privacy and data protection rights of all our donors. If you are a citizen of the UK or the EU, you can contact us through one of the following:
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1-800-xxx-xxxx
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or email us at privacymanager@lesaints.org
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or write to us at: Data Privacy Manager; Le Saints, 285 Peachtree Center Ave NE #2700, Atlanta, GA 30303
Personal Data or categories of personal data that we process:
We provide our donor community with a number of options to get involved and support the work of Le Saints including through online donations, performed through our website or social media.
Depending on how you have chosen to communicate with us and to ensure we can provide you with information that is relevant and of interest to you we generally process the following categories of personal data:
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Name (first name and family name)
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Prefix
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Address
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Email Address
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Job title for employees of institutional donors
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Data regarding the donation: amount of donation, purpose of donation, date of donation
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History of previous donations
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History of donor and interests regarding our organization and its purposes
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Members of your household, if they are giving to our organization or have shown interest in our organization
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Language preference
In case we have direct personal contact with you throughout our donor relationship, we might process further data, as it is shared by you or gained from publicly available resources:
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Phone number
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Date of birth
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Age
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Gender
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Job title, profession
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Place of work
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Information about the content and channel of communication, date, reason, and result of our interactions with you
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Your personal preferences and areas of interest with regards to our organization and its purposes
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Le Saints events that you and your family have attended
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General publicly available information
Within our research, we also gain publicly available information through various publicly non-intrusive accessible sources and may process personal data in line with the purpose of the source.
Purposes of processing your personal data and lawful bases
Through your gift(s), you have expressed support and interest in our work. Our work would not be possible without the voluntary contributions we receive, such as the one you are making. Through the following chart, we are providing you with the purposes and lawful bases of our processing activities, which are among others:
Recipients or categories of recipients of your personal data
We do not share your data with any third parties for promotional purposes.
Within Le Saints, access to your personal data is only given to individual members of staff or teams in order to fulfill our legal and contractual obligations as well as for the above-described purposes.
Your personal data may be shared with service providers that we engage as processors. If we do so, we will always enter into data processing agreements including all the legal obligations of Art. 28 GDPR. Such processors can be the following (this list is not exhaustive, and we reserve the right to change service providers):
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service providers that we use for our collection and processing of data in our database, our communication with you, online or in print
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public institutions and authorities regarding our legal reporting obligations (such as tax authorities, federal bank)
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service providers whom we use to process your donation
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service providers we use for the maintenance and support of our IT systems
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service providers we use for our internal financial accounting systems, compliance systems, data screening within legal obligations and audits.
Time of storage of your personal data
We delete your personal data when the legal basis for maintaining the data has/have expired and the processing and storage of your personal data is no longer necessary. This is usually the case after we have had no giving or no contact from your side for more than 2 years, unless we are bound to extend the storage for legal reasons.
Your data protection rights
You have the following rights based on the GDPR:
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Access Right (Art. 15 GDPR)
You have the right to request access to the personal data that we process about you. -
Right to rectification (Art. 16 GDPR)
In case we process inaccurate personal data about you, you have the right to rectification. -
Right of erasure, restriction and objection (Art. 17, 18 and 21 GDPR)
If the legal requirements of Art. 17, 18 or 21 GDPR are met, you have the right to erasure of your personal data, the right to restriction of processing, and the right to object to the processing of your personal data. -
Right to data portability (Art. 20 GDPR)
If you have given your consent to the processing of your personal data or we are processing on the basis of a contract and the processing is carried out by automated means, you have the right to transmit those data to another controller.
Your right to withdraw your consent
You have the right to withdraw any consent you have given at any time for the future by email or mail to the addresses set forth above. This withdrawal does not affect the lawfulness of processing of your personal data that has taken place prior to your withdrawal.
Transfer of data in third countries or international organizations
We only transfer personal data in countries outside of the EU and the EEA (European Economic Area), so-called “third countries,” in the following cases: necessity for the performance of your orders, legal requirements (duty to report to tax authorities), based on your consent, or necessity within a processing agreement that we have with a service provider.
Obligation to provide personal data when required for a contract
We need certain personal data from you to be able to perform the donor relationship and to fulfill our contractual and statutory legal obligations. Without this personal data, we cannot conclude the donor contract with you or continue an existing contractual donor relationship.
Contact - Data Protection Officer
If you wish to exercise any of your rights mentioned herein or have any questions about this policy, please contact the Data Protection Officer:
1-800-xxx-xxxx
or email us at privacymanager@lesaints.org
or write to us at: Data Privacy Manager; Le Saints International; 28
