World Connect International, UK Privacy Policy

 

The following privacy policy (the "Privacy Policy") outlines what information World Connect International ("World Connect", "we" or "us") may collect from users when you call, email, or otherwise communicate with us or our website https://www.worldconnect.org.uk/ (the "Site"), any of its subdomains, or any related sites, applications, widgets, or online services offered by World Connect (collectively, the "Service" or "Services"), and how we protect, use and disclose that information, and what choices you have about how that information is used and disclosed. We are a registered charity under charity number 1194944 and have our registered office at 21 Greswell Street, London SW6 6PR.

This Privacy Policy is subject to the Service's Terms of Use ("Terms of Use") currently located at https://worldconnect.org.uk/terms-of-use or as updated on the Site from time to time. Because our Services interact with numerous third party services, it is your responsibility to read and accept the terms of use and privacy policy of each such third party sites or services prior to your use of, or interaction with, such services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICE. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT USE THE SERVICE.

When you use the Services, you understand that World Connect may collect, use and disclose technical data and related personally identifiable information about you ("Personal Information") in various ways subject to the terms of the Privacy Policy. By using the Services, you accept the terms of this Privacy Policy and the Terms of Use and consent to our collection, use, disclosure and retention of your Personal Information as described in this Privacy Policy. We keep the Privacy Policy under regular review and we reserve the right, at our sole discretion, to modify or replace this Privacy Policy at any time in accordance with Section 11. (Changes to This Privacy Policy). If you have questions about this Privacy Policy, please contact us at the contact information listed in Section 13. below.

We will use all reasonable efforts to process Personal Information relating to data subjects within scope of the UK General Data Protection Regulation ("GDPR") in compliance with such laws. These data subjects have the right to be informed of when their data is collected and how it is being processed, in addition to the following rights:

• The right to access. (See Section 5.)

• The right to be forgotten. (See Section 5.)

• The right to have information corrected. (See Section 5.)

• The right to restrict processing. (See Section 6.)

• The right to object. (See Section 6.)

• The right to be notified. (See Section 8.)

1. ELIGIBILITY REQUIREMENTS

World Connect does not knowingly collect or solicit Personal Information associated with, or used to identify or contact, anyone under the age of 13 or knowingly allow such persons to register on the Services or make donations. If we learn that we have collected Personal Information from anyone under the age of 13, we will delete that information. If you believe that anyone below that age has provided personal information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.

2. INFORMATION COLLECTED BY WORLD CONNECT

Upon registration with the Services, a user profile is developed to further customise the user's experience. We collect Personal Information you actively enter onto our online forms during registration or while using the Services.

2.1 Information We Collect From You

When you register on, or otherwise use the Services or visit our retail site, we may collect information you provide via forms, surveys, applications or other online fields including:

• Email

• Name

• Billing Address

• IP address

• Other payment information

• Any additional information submitted by you via forms, surveys, applications, or other online fields, including contact information and personal messages

Our third party card processor stores all credit card information. It conducts the entire credit card transaction using industry standard 128 bit SSL encryption. We store only a record that the transaction took place. In the United Kingdom, you may have the right to withdraw consent for certain uses and certain additional rights, which are detailed at Section 5. below.

2.2 Cookies, Beacons and Other Technology used by World Connect

To help us serve your needs better, when you visit the Site or use the Services, we may collect certain non-personal usage data from you, including your browser type, operating system, the specific web pages visited during your connection, and the domain name from which you accessed the Site or Services. In addition, we may collect information about your browsing behavior, such as the date and time you used the Site or Services, the areas or pages of the Site or Services that you visit, the amount of time you spend viewing the Site or Services, the number of times you return to the Site or Services and other clickstream data.

This usage data is stored and tracked using "cookies". A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. A website can use cookies to recognise repeat users or track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. Users of the Services should be aware that non-Personal Information and data may be automatically collected by virtue of the standard operation of World Connect computer servers or through the use of cookies. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. There may, however, be some features of the Services which require the use of cookies in order to customise the delivery of information to you. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.

Users should be aware that World Connect cannot control the use of cookies (or the resulting information) by third parties. The use of third party cookies is not covered by our Privacy Policy. We do not have access to or control over these cookies. We may also use web beacons to access our cookies. A web beacon is an electronic file on a Web page that allows us to count users who have visited that page and to recognise users by accessing our cookies. Further, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness. You can avoid web beacons by turning off HTML display and displaying only the text portion of your email.

World Connect does not track users across third party websites, and therefore does not use or respond to "do not track" signals in your web browser. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain website browsers allow you to set the "do not track signal" on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

We may participate in behavior-based advertising. This means that a third party may place a cookie on your browser, or use a web beacon, to collect information about your use of our website so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on our website, or on other websites. If you would like to opt-out from having the behavioral-based advertising companies with whom we have a relationship use your information for advertising purposes you can do so by visiting the Network Advertising Initiative or Digital Advertising Alliance. You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit: http://www.youronlinechoices.eu/ or http://www.allaboutcookies.org.

We also use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to assist in providing the Services. Google Analytics uses cookies to help us analyse how users use the Services. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to, and stored by, Google on their servers and we do not share it with anyone else. Google will use this information for the purpose of evaluating your use of the Services, compiling reports on website activity for us and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Services. By using the Services, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

3. HOW WORLD CONNECT USES YOUR INFORMATION

3.1 Purposes for which we will process your Personal Information

We will only use your Personal Information for the purposes for which we collected it, as set out below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We will communicate with you by email or telephone, in accordance with your wishes. By providing a telephone number, you consent to us contacting you at that number for the purposes outlined in this Privacy Policy. You may revoke your consent to be contacted at any time by emailing us at [email protected].

Please note that we may process your Personal Information without your knowledge or consent where this is required or permitted by law.

We have set out below, in a table format, a description of the purposes for which we may use your Personal Information, and which of the lawful bases we rely on to do so.

Purpose	Lawful Basis
To provide you with the Services and support, enhance your use of the Services, communicate with you, allow you to evaluate your eligibility for such products or services, monitor which features of the Services are used most and allow us to determine which features we need to focus on improving.	For the performance of a contract with you. Necessary for our legitimate interests (to provide our services to you and to continually improve our services for other participants).
To process donations and payments that you make via the Site, which shall also be processed by our third party provider as further described at Section 3.2 below.	For the performance of a contract with you. Necessary for our legitimate interests (to process donations made to us for the purpose of conducting our charitable business).
To process applications for grants or project launches.	For the performance of a contract with you. Necessary for our legitimate interests (to provide grants and launch projects pursuant to our charitable objectives).
To help diagnose problems with our computer server, and to administer the Site. Your IP address can also be used to gather broad demographic data. It is not stored or linked to your personal profile information, such as name or contact information.	For the performance of a contract with you. Necessary for our legitimate interests (to continually improve our website for the purpose of providing our services).
To send you strictly Service-related announcements on rare occasions when it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, please let us know via email.	For the performance of a contract with you. Necessary for our legitimate interests (to provide our services to you and to continually improve our services for other participants).
To better understand how users access and use the Service, in order to improve the user experience and address user preferences. We may also use the information we collect from you to help develop new services or products or improve existing services or products.	Necessary for our legitimate interests (to provide our services to you and to continually improve our services for other participants).

When you register online on the Service, you may be given the option of receiving periodic informational or promotional mail or e-mail from World Connect. At any time, you can 'unsubscribe' yourself from our email list simply by clicking the 'unsubscribe' button.

We also use aggregated, non-Personal Information collected from users of the Services, so that we can improve the Services and for business and administrative purposes.

3.2 Donor Information

All donations and payments that we allow you to make via the Site will be processed by third party payment processing services such as PayPal, Inc. The credit card, billing information, or other information that you provide during the payment or donation process is not stored on our servers and is handled by such third party payment processing services, in accordance with the Payment Card Industry Data Security Standard (“PCI DSS”). It is your responsibility to read and accept the terms of use and privacy policy of each such third party sites or services prior to your use of, or interaction with, such services. While we will seek to require such third parties to follow appropriate privacy policies, we do not bear any responsibility for any actions or policies of third parties. You can find more information about PCI DSS here https://www.pcisecuritystandards.org/security_standards/index.php.

4. OUR DISCLOSURE OF YOUR INFORMATION

We may disclose your Personal Information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

4.1 Aggregated Data

World Connect may share aggregated usage and log data collected from users of the Services with third parties for industry analysis and demographic profiling, but such aggregated data will not include any Personal Information.

4.2 Third Party Service Providers

We may employ third party companies and individuals to facilitate our provision of the Service, to provide the Service on our behalf, provide customer support, perform Service-related services (e.g., payment processing, maintenance services, database management, web analytics and improvement of the Services' features) or to assist us in analysing how our Services are used. These third parties may have access to your Personal Information, but only to the extent needed to perform these tasks on our behalf. If you choose to purchase merchandise, products and/or services, or donate on or through any such third party companies, the information may be used by such third parties, each pursuant to its own policies. There are also times when you provide information about yourself to us in areas of the Service that may be managed or participated in by third parties. We may also provide your information to our advertisers, so that they can serve ads to you that meet your needs or match your interests. While we will seek to require such third parties to follow appropriate privacy policies and will not authorise them to use this information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.

4.3 Law Enforcement and Legal Purposes

World Connect cooperates with government and law enforcement officials, agencies and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials, agencies or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect the property and rights of World Connect or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical or legally actionable activity.

World Connect may share information we collect from you, as needed, to enforce our rights or protect the rights of others, or as needed to support external auditing, compliance and corporate governance functions.

4.4 Business Transfers

In the event that all or a substantial portion of the assets, or business of World Connect are acquired by, merged with or transferred to another party, or in the event that World Connect goes out of business or enters bankruptcy, your Personal Information may be one of the assets that is transferred to or acquired by the third party. You acknowledge that such transfers may occur, and that any acquirer of World Connect or its assets may continue to use your Personal Information as set forth in this Privacy Policy. If any acquirer of World Connect or its assets will use your Personal Information contrary to this Privacy Policy, you will receive prior notice.

5. ACCESSING, CORRECTION and DELETION OF YOUR PERSONAL INFORMATION

You have the ability to access and correct your personal information. You may access your personal information by signing into your account. From there, you can correct or modify your information. You may also exercise your rights, subject to applicable laws, to request that we correct, delete or restrict access to your personal data. We may need to retain your data for legally permitted purposes, as further described in Section 7. below, and this will be explained to you if necessary. We will provide data portability, which means you may also obtain your personal information from World Connect in a structured, commonly used and machine-readable format and reuse it elsewhere, or request that we transmit your Personal Information to another data controller.

If you need assistance correcting or updating your personal information, or would like to request that we delete your personal information, please contact us using the contact information detailed in the "Contact Us" section below.

In response to a request for you to exercise your rights, we may ask you to verify your, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

6. OBJECTION TO AND RESTRICTION OF PROCESSING OF PERSONAL INFORMATION

You may ask World Connect to stop processing your Personal Information. We will stop processing unless we can demonstrate compelling legal grounds for the processing.

You can also request that we restrict our processing of your Personal Information. You may exercise this right at any time by emailing us at [email protected].

7. RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified.

8. SECURITY

It is our policy to protect your account information against unauthorised access, use, loss or release and we have put in place appropriate technical and organisational measures to do so. However, we cannot guarantee the security of our database, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet, and any information you transmit to World Connect you do at your own risk. In order to protect you and your data, we may suspend your use of the Services without notice, to mitigate harm and facilitate an investigation, if a security breach is suspected. We will promptly notify you and all applicable regulators of a suspected breach where required by applicable law.

In addition, we have procedures that limit World Connect employees and contractors' access to Personal Information. Only those employees and contractors with a business reason to know have access to such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, mandatory training programs, and internal policies on data privacy and corporate integrity. We take appropriate disciplinary measures to enforce employee privacy responsibilities.

9. DATA TRANSFER TO THE UNITED STATES

This Privacy Policy is intended to cover collection of information from data subjects in respect of the United Kingdom. The Service and the services upon which the Service is hosted are provided from the United States. If you choose to provide us with Personal Information, you consent to the transfer and storage of that information on our servers located in the United States. Where we disclose or otherwise transfer Personal Information from the United Kingdom to outside the United Kingdom, including the United States, we will ensure where necessary that appropriate safeguards are in place for the protection and security of such Personal Information in compliance with the UK GDPR. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By visiting the Site and submitting Personal Information, you authorise this transfer.

10. THIRD PARTY LINKS

We may provide links to third party websites, such as credit bureaus, service providers, social media websites and applications, or merchants ("Third Party Services"). A link to any Third Party Service does not mean that World Connect endorses it or the quality or accuracy of information presented on it. If you follow links to sites not affiliated or controlled by World Connect, you should review their privacy and security policies and other terms and conditions. World Connect does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website and in the Portals prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

12. RIGHT TO LODGE COMPLAINTS

We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with the UK Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

13. CONTACT US

If you have questions or concerns regarding this Privacy Policy, you should contact us at:

World Connect International
Attention: Patrick Hidgon
21 Greswell Street,
London SW6 6PR
[email protected]