Last Updated: July 10th, 2020
1. Introduction & Scope
- Vision for Israel is committed to protecting the privacy and security of your personal information (collectively referred to as “the Company”, "we", "us" or "our").
- This Privacy Notice (“Notice”) describes how we collect and use personal information about you during and after your relationship with us in accordance with the General Data Protection Regulation (“GDPR”).
- This Notice applies to all our website and online application users, donors, volunteers, and subscribers to our newsletters located in the United Kingdom (“UK”) or European Union (“EU”), and the rest of the world, whether past, present or prospective and including any relevant third parties such as your permitted agents or representatives.
- It is important that you read this Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information. This Notice does not form part of any contract to provide services you may have with the Company from time to time.
- We reserve the right to amend this Notice at any time without notice to you so, if required, please check to ensure that you are referring to the latest copy of this Notice. We may also notify you in other ways from time to time about the processing of your personal data.
2. Data Controller
- Vision for Israel is made up of different legal entities, including:
- This Notice is issued on behalf of the Vision for Israel group of companies, so when we mention “Vison for Israel”, “the Company”, “we”, “us” or “our” in this Notice, we are referring to the relevant company within Vision for Israel responsible for deciding how we hold and use personal information about you.
- Each of our entities has appointed a “Data Privacy Manager” to oversee compliance with this Notice. If you have any questions about this Notice or how we handle your personal information, please contact [firstname.lastname@example.org] and the relevant Data Privacy Manager will contact you further.
- You have the right to make a complaint at any time to the regulatory body of your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach any regulator so please contact us in the first instance.
- In so far as the main UK and EU jurisdictions in which we operate, the supervising authorities are:
Netherlands - Autoriteit Persoonsgegevens (https://autoriteitpersoonsgegevens.nl)
3. The kind of information we hold about you
- Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are also "special categories" of more sensitive personal data which require a higher level of protection.
- We may collect, use, store, and transfer different kinds of Personal Data about you which we have grouped together as follows:
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Our website and online applications are not intended for children and we do not knowingly collect data relating to children.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
4. How is your personal information collected?
- We collect personal information about you when you correspond with us directly either by filling in our forms or by contacting us by post, phone, email, or in person. We may also collect personal information about you from publicly available sources. This specifically includes personal data you provide when you:
- We also automatically collect personal information about you when you receive our newsletters and as you interact with our website and online applications including data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies, as almost all websites, newsletters, and online applications do, to help provide you with the best experience we can. Please note that the websites and online applications that we are responsible for include:
5. How we will use information about you
- We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- We may also use your personal information in the following situations, which are likely to be rare:
- Generally, we do not rely on consent as a legal basis for processing your personal data and we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. However, we do require your consent to contact you from time to time with our newsletter, some marketing content, and on occasion information about our services.
- We will obtain your consent to contact you when you subscribe to our newsletters or as part of our direct communications with you. At that time, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us.
7. Situations in which we will use your personal information
- We need all the categories of information set out in paragraph 3 above primarily to allow us to manage our relationship with you and to enable us to comply with our legal obligations. We may also use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
- The situations in which we will most commonly process your personal information are listed below:
7.2.1 to collect and manage your donations;
7.2.2 to register you as a volunteer for our projects and to correspond with you regarding our volunteering activities;
7.2.3 to facilitate the sale of goods or services from our online stores;
7.2.4 to keep you updated with news and information about our charitable activities in Israel and the furtherance of our core charitable objectives which include fundraising, marketing and relationship building communications with you;
7.2.5 to manage the payment of fees and charges;
7.2.6 to respond to, or follow up on, your comments and questions, and otherwise provide customer service;
7.2.7 to create promotional material using photographs or attendance information taken at our events;
7.2.8 complying with health and safety obligations;
7.2.9 updating and enhancing our donor, volunteer and sales records;
7.2.10 analysis for management purposes and the improvement of our services;
7.2.11 administering and protecting our business, website and mobile applications;
7.2.12 asking you to leave a review or take a survey;
7.2.13 enabling you to partake in a prize draw, competition or complete a survey;
7.2.14 delivering relevant website and third party content to you and measure or understand the effectiveness of the content we serve you;
7.2.15 using data analytics to improve our website, services, marketing, and experiences;
7.2.16 to make suggestions and recommendations to you about goods or services that may be of interest to you;
7.2.17 crime prevention; and/or
7.2.18 legal and regulatory compliance.
- Some of the above grounds for processing will overlap and there may be several grounds that justify our use of your personal information.
8. Marketing and Newsletters
- You will receive news and marketing communications from us if you have requested information from us by subscribing to our newsletters, made a donation, or if you provided us with your details in some other capacity and, in each case, you have not opted out of receiving that marketing.
- We may use your personal information to form a view on what we think may be of interest to you. This is how we decide which services to provide and which of our charitable objectives to provide you with information on.
- You can ask us to stop sending you marketing messages at any time by following the ‘unsubscribe’ links on any marketing message sent to you or by contacting us at [email@example.com]. Please note that where your personal data has been supplied to a third party, in accordance with this Notice and they are using your data in a capacity as a “joint controller”, you may also have to contact them directly in order to change your communication preferences.
- Please note where you opt out of receiving marketing messages, we may still process your personal data, in compliance with the above rules, where this is required or permitted by law.
9. If you fail to provide personal information
Where we need to collect personal data by law, or under the terms of an agreement we have or are trying to enter into with you and you fail to provide that data when requested, we may not be able to administer your donation, your request to volunteer, or perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel the agreement you have with us but we will notify you if this is the case at the time.
10. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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.
11. Automated decision-making
We do not envisage any decisions will be taken about you by automated means, however, we will notify you in writing if this position changes. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
12. Data sharing
- We may have to share your Data with third parties. We will only share your Personal Data with third parties where required by law, where it is necessary to administer your relationship with us or where we have another legitimate interest in doing so.
- "Third parties" includes third-party service providers such as our contractors, suppliers, and designated agents. We may also need to share your personal information with a regulator or to otherwise comply with the law.
- Most commonly, we will need to share your data with the following parties for the following purposes:
- Any third parties in the UK and the EU are subject to the provisions of the GDPR or similar regulations in relation to your personal data. They are required to take appropriate security measures to protect your personal information and we do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
13. Joint Controllers
- As set out above, we may share your data with other entities within the Vision for Israel group. Each party shall be considered a “joint controller” for the purposes of the GDPR which means that the parties may jointly determine the purposes and means of processing your personal data.
- Generally, the parties will only share personal information in connection with the management of Vision for Israel, in compliance with their own legal obligations, and the enforcement and administration of justice. However, each party may use your personal data for their own independent purposes where this is required or permitted by law.
- Each party is responsible for its own obligations as a ‘controller’ under the GDPR but if you have any questions about how your data may be shared within the Vision for Israel group please contact the Data Privacy Manager.
14. Third-party links on our Website
- Our website may include links to third-party websites, plug-ins, and applications from our partners, members, advertisers, or affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
- Similarly, if you take up any offers or promotions with our affiliates, those third parties may pass information on to their own suppliers once we have provided it to them. We are not responsible for personal data that is used by such third parties in their capacity as independent or joint ‘data controllers’.
- When you leave our website or otherwise engage with third-parties, we would urge you to read the privacy notice of every website you visit to ensure you are fully informed of all data processing activities connected with the services you receive from us.
15. Transfers outside the EU
- Vision for Israel is an international organization and so your data may be transferred outside the EU. The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. We transfer personal data originating in one country across borders when we transmit, send view or access that data in or to a different country.
- We will only transfer Personal Data outside the EEA if one of the following conditions applies:
- We currently engage the Rocket Science Group LLC (trading as “MailChimp”), a US company, to maintain our online email databases and to allow us to keep in contact with you, primarily by sending emails. MailChimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and is committed to protecting all personal information received from us. We have entered into appropriate contractual arrangements with MailChimp in order to ensure the security and proper use of your data but if you have any questions about this, please contact the Data Privacy Manager directly. A link to MailChimp’s own privacy notice can be found here: https://mailchimp.com/legal/privacy/
- Please contact the Data Privacy Manager if you want further information about when we may transfer your information outside the EEA and the specific mechanisms used by us to ensure the protection of your personal data.
16. Data security
- The GDPR requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We ensure that reasonable security measures are taken against unlawful or unauthorized processing of personal data, and against the accidental loss of, or damage to, personal data.
- We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- If you have any questions about our current organizational and technical security procedures, please contact the Data Privacy Manager.
17. How long will you use my information for?
- We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Details of retention periods for different aspects of your personal information are available on request from the Data Privacy Manager.
- In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure, and restriction
18. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
19. Your rights in connection with personal information
- Under certain circumstances, by law, you have the right to:
- If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact the Data Privacy Manager in writing.
20. No fee usually required
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
21. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
22. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Privacy Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.