Privacy Policy

EFFECTIVE DATE: JUNE 8, 2020

Privacy Policy

Embers International, Inc. (“Embers International”) values your privacy. We do not rent or sell your personal information with any person, business or organization. We commit to uphold transparency, accountability and choice regarding the collection of your personal information. We are committed to using the personal information you provide to only support your relationship with Embers International. We have business processes to ensure that personally identifiable data is accurate and complete. These business processes are in accordance with Embers International’s privacy policy and serve to support your relationship with Embers International.

This privacy policy describes how Embers International collects and uses the personal information you provide, whether online or offline. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. Visitors to https://www.embersinternational.org/ can browse our website without providing any personal information.

 

1) CONTACT INFORMATION OF THE CONTROLLER

 

Embers International, as the data controller, is located at 2050 Center Avenue, Suite 320 Fort Lee NJ 07024. If you have questions or complaints regarding our privacy policy or practices, please contact us at (201) 482–0749 or via email at info@embersinternational.org.

 

2) COLLECTION AND USE OF PERSONAL INFORMATION

 

Collection and use of personal information in connection with your donations and any services provided to you by Embers International.

 

Purpose And Legal Basis Of Processing

 

i) Art. 6 (1) a) GDPR (processing is based on your consent)

 

Only if you provide us your consent (which is revocable at any time), we process personal information from you for marketing and communications purposes or to facilitate your participation in Embers International events or activities in which you voluntarily engage.


ii) Art. 6 (1) b) GDPR (processing is necessary for the performance of a contract)

In order to communicate with you and for the performance of our contractual obligations to you (for example, to process your donation, issue receipts, and otherwise support your relationship with Embers International), we may collect the following personal information from you:

  • Contact information such as name, e-mail address, mailing address, and phone number
  • Billing information such as credit card number and billing address
  • Unique identifiers such as user name, account number, and password
  • Additional information as needed to support your relationship with Embers International, such as age or DOB (to ensure age appropriate content) and tax-payer information (to support tax recovery)


iii) Art.6 (1) c) GDPR (complying with a legal obligation)

In certain circumstances we are obliged to process personal data from you due to a legal obligation, such as anti-corruption stipulations or statutory retention periods.


iv) Art.6 (1) f) GDPR (legitimate interest in transmitting personal data)

We primarily rely on the legitimate interest of Embers International to provide constituents with desired information about Embers International and its work worldwide. Where we process your personal information on the basis of legitimate interests, including sharing of your personal information within Embers International or with third party processors for such purpose, we do so primarily to provide and improve constituent services and provide constituents a service which is suitable to their requirements. We may use your information to improve and customize our constituent services, and as necessary to pursue our legitimate interests of improving our constituent services and experience; understanding how constituents engage with Embers International, communicating with constituents in appropriately customized ways, and exploring ways to better engage current and future constituents in the mission of Embers International. We may also process your information for our legitimate interest in providing age appropriate content for children; supporting tax recovery; and maintaining the safety and security of our constituent services, including enhancing protection against spam, harassment, intellectual property infringement, crime, and security risks of all kind. We may further process personal information of constituents who attend in person events or trips for our legitimate interest in providing for the safety and security of all event attendees. Embers International has further legitimate interests in processing your personal information as follows:

  • We may process personal data from you in order to defend legal claims.


Additionally, we may collect the following personal information from third party sources, including from public sources:

  • Marketing information such as additional forms of contact, indicators or flags used for segmentation purposes.
  • Demographic information, including census data or third-party research for segmentation purposes.


Surveys Or Contests

From time-to-time we may provide you the opportunity to participate in contests or surveys on our website or elsewhere. If you participate, we will request certain personal information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). The legal basis for processing that personal data is Art.6 (1) a) GDPR (consent).

  • Collection And Use Of Personal Information In Connection With Your Use Of Our Website


Informational Use Of Our Website

If you do not register with us or otherwise provide us with personal information, we only process the personal information that your browser transmits to our server. This includes your IP address, date and time of the request, time zone difference to Greenwich Mean Time (GMT), content of the request (specific page), the access status/HTTP status code, the amount of data transferred in each case, website from which the request comes, browser, operating system and its surface, language and version of the browser software. This processing is technically necessary for us to display our website to you and to ensure the stability and security of the website. The legal basis for such processing is Art.6 (1) f) GDPR.


Cookies

By using this Website, you consent to us using 'cookies' and similar technologies that can track your activity. Cookies are small pieces of information sent by a web server to a web browser (e.g. Internet Explorer, Safari, Google Chrome or Firefox) on the computer or device you use to access this Website, which enables our server to collect information from your device browser.


Enabling some of these cookies is not strictly necessary for the Website to work but it should enable us to provide you with a better browsing experience. Cookies can be deleted or blocked through changing your web browser settings, however some features of the Website may not work as intended and you may not be able to access parts of the Website. The cookie-related information will not be used for personal identification of individuals and data relating to usage patterns on our Website is kept under our control. These cookies will be used for the following purposes:

  • to improve Website usability;
  • so we can remember your device or computer between successive actions or sessions; and
  • to perform anonymous statistical analysis to improve functionality of our Website or any services we offer through the Website.


Please note that when accessing the web and clicking on third party links that may be provided when using our site, those third parties (including, for example, providers of external services that are relevant the Services we offer) may also use cookies on their websites, over which we have no control.


Links To Other Websites

Our Site includes links to other websites whose privacy practices may differ from those of Embers International. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.


Analytics

This website collects personal data to power our site analytics, including:

  • Information about your browser, network, and device
  • Web pages you visited prior to coming to this website
  • Your IP address

This information may also include details about your use of this website, including:

  • Clicks
  • Internal links
  • Pages visited
  • Scrolling
  • Searches
  • Timestamps

We share this information with our website analytics provider, to learn about site traffic and activity.


3) RECIPIENTS OF YOUR PERSONAL INFORMATION


We do not sell your personal information to third parties. We will share your personal information with third parties only in the ways that are described in this privacy policy. In those situations where we use a third party to process your data, we require that these third parties agree to provide the equivalent level of protection as provided under the applicable data privacy law and this privacy policy. Third parties may be suppliers that process personal data on our behalf, such as:

  • IT service providers
  • Companies that assist with customer service, shipping, or event registration
  • Companies that provide other services to support our relationship with you
  • Companies that provide demographic and market research assistance

Specific to donations, Embers International uses third party processors, including, without limitation, Squarespace, Stripe, Aplos, and Paypal, (collectively “TPP”) to gather donor’s data from financial institutions. By using our service, you grant Embers International and its TPP the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by TPP in accordance with their respective privacy policy.


We may also disclose your personal information to third parties:

  • as required by law such as to comply with a subpoena, or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; or
  • with your prior consent to do so.


4) GENERAL INFORMATION AND YOUR RIGHTS


Donor Portal

Embers international maintains a donor portal, available at: https://www.aplos.com. From the donor portal, donors may change their own personal information.


Choice/Opt-Out

Where you have provided your consent, you have the right to withdraw your consent to our processing of your personal information. For example, you may choose to stop receiving all or certain types of communication by following the unsubscribe instructions included in these emails or you can contact us at info@embersinternational.org. You can further choose to withdraw your consent to our processing of your personal information related to an online account (e.g., donor portal) by closing your account through your account settings and then emailing info@embersinternational.org to request that your personal information be deleted, except for information that we are required to retain. This deletion is permanent and your account cannot be reinstated.


Correcting, Deleting and Updating Your Personal Data

To review and update or delete your personal information, contact us at info@embersinternational.org. We will respond to your request to access within 10 days. If you are a donor, you may use our donor portal to update your personal information.


Customer Testimonials/Comments/Reviews

We may post customer testimonials/comments/reviews on our website which may contain personal information. We do obtain the customer's consent via email prior to posting the testimonial to post their name along with their testimonial. If you wish to update or delete your testimonial, you can contact us at info@embersinternational.org. The legal basis for that processing is Art.6 (1) a) GDPR.


Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us as described in this policy. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at info@embersinternational.org. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).


Transaction Security

The personal information collected when you make a contribution or purchase items by credit card is kept for the purposes of tracking your order and to provide a receipt of the transaction. This information is stored on an encrypted, secure server managed by a third-party commercial credit card processing institution.


Notification Of Privacy Policy Changes

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


Your Rights In Respect of Your Personal Data

You have the right of access (Art.15 GDPR), rectification (Art.16 GDPR), erasure (Art.17 GDPR), restriction of processing (Art.18 GDPR) and the right to data portability (Art.20 GDPR). In addition, you have the right to object to processing that is based on Art.6 (1) f) GDPR. You also have the right to lodge a complaint with the data privacy supervisory authority.


If you have given us your consent to process personal data for specific purposes, this consent is the legal basis for processing your personal data. Consent can be revoked at any time without affecting the legality of the processing carried out on the basis of the consent until revocation. The revocation can take place form-free and should be directed if possible, to the contact information provided in this policy.


Contact Information

Embers International, Inc. 

2050 Center Ave. Suite 320 

Fort Lee, NJ 07024 

Email: info@embersinternational.org 

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