Echoing Green Privacy Policy

Last updated 8/14/2018

Purpose of this privacy policy

We at Echoing Green appreciate the importance of your privacy and we are fully committed to the protection of your personal information.

This privacy policy explains Echoing Green’s policies and practices regarding its processing of your personal information, and explains your privacy rights under applicable privacy laws. Please note that this privacy policy is also incorporated into the Echoing Green Terms of Use.

Controller

If you reside in the EU, the data controller (as defined under EU data protection law) will be Echoing Green, Inc.

Contact details

If you would like further information on anything in or related to this privacy policy, or you would like to exercise any rights that you may have in relation to your personal information, please contact us here using the category “Privacy.”

Changes to the privacy policy and your personal information

Echoing Green may make non-significant changes to our privacy policy from time to time. If we make any significant changes to our privacy policy we will notify you by posting on our website, or by emailing you if we have your email address for such purposes and depending on the changes we make.

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us by managing your information here or by contacting us here using the category “Privacy.”

Third-party links

The Echoing Green website contains links to third-party websites that contain articles or blogs of interest, or that manage the Fellowship applications and donations to Echoing Green. Clicking on such links 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 practices. We encourage you to read the privacy policy of every website you visit.

1. Personal Data That We May Collect About You

Depending on your interests and interactions with us and what you choose to provide, we may collect, use, store and transfer various types of personal data about you, such as:

  • Identity Data: e.g., your names, username or similar identifier, marital status, title, company, date of birth, gender, national citizenship, race, ethnicity, and photograph.
  • Contact Data: e.g., your home or work addresses, email address, and telephone numbers.
  • Financial Data: e.g., bank account details, payment card details, invoices, amounts paid by us or due to us, your billing address, and amounts of any donation or payment you make to us.
  • Technical Data: e.g., your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or other websites managed by Echoing Green.
  • Profile Data: e.g., your education, experience and achievements, your interests, objectives, preferences, feedback, questions, complaints, comments, and information relating to your organization.
  • Usage Data: e.g., information about how you use our website, collected using cookies (further described in the “Cookies” section below.
  • Marketing and Communications Data: e.g., your preferences in receiving marketing from us.

Depending on what information you choose to provide, we may also collect 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) that you submit to us in connection with any application that you make to us. We may also collect certain information about criminal convictions and offenses. We will only process this personal data in accordance with applicable laws.

2. When We May Collect Your Personal Data

We collect the types of personal data described above depending on your actions, such as when:

  • You apply to participate in an Echoing Green program: you may give us your Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data
  • You apply for a career with Echoing Green: you may give us your Identity Data, Contact Data and Profile Data
  • You apply, bid, or propose to provide services to Echoing Green: you may give us your Identity Data, Contact Data and Financial Data
  • You contact us through our website: you may give us your Identity Data, Contact Data, Profile Data, and Marketing and Communications Data
  • You sign up to receive our monthly newsletter or other updates or information from us: you may give us your Identity Data, Contact Data, Profile Data and Marketing and Communications Data
  • You donate to Echoing Green: you may give us your Identity Data, Contact Data, Financial Data, and Marketing and Communications Data
  • You provide recommendations or advice to Echoing Green: you may give us your Identity Data, Contact Data and Profile Data
  • You complete a survey for Echoing Green: you may give us your Identity Data, Contact Data, Profile Data and Marketing and Communications Data
  • You browse our website, including to interact with us in any of the ways listed above: you may (in addition to the categories described above) give us Technical Data and Usage Data
  • You interact with us at our events or correspond with us by mail, phone, email or otherwise: You may give us your Identity Data, Contact Data, Financial Data, Profile Data and/or Marketing and Communications Data

3. How We Use Your Personal Data

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we expect to use your personal data, and the bases we rely on to do so.

Purpose/Activity

Type of data

Lawful basis for processing

To process your application to become an Echoing Green Fellow, participate in an Echoing Green program or work at Echoing Green

  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications

Legitimate interests

  • Getting to know applicants to our Fellowship program and supporting successful applicants to help them achieve their visions
  • Getting to know employees or potential employees / workers / consultants
  • Fulfilling our staffing requirements
  • Ensuring potential recruits of any kind are appropriately qualified for their positions

Your consent

  • In respect to any marketing information you want us to send you

Legal obligation

  • We have a legal obligation to verify your right to work lawfully for us

To respond to any questions, complaints or feedback that you provide to us

  1. Identity
  2. Contact
  3. Profile

Legitimate interests

  • Responding to your communications with us
  • Getting to know you and growing our network
  • Maintaining, managing, and improving our website and programs

To send you requested information about us, our programs, and events

  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications

Your consent

  • In respect to any marketing information you want us to send you

Legitimate interests

  • Sharing information about our goals and activities
  • Ensuring that we only send you information that you request
  • Monitoring the uptake of our newsletter, program updates and other information
  • Informing our marketing strategy

Processing any donation or funding you make to Echoing Green and carrying out fundraising activities

  1. Identity
  2. Contact
  3. Financial
  4. Profile

Contract

  • To fulfill our requirements of any funding agreement that we have with you

Legitimate interests

  • Identifying and attracting funding for our aims and objectives
  • Collecting and dedicating the donations and funding that we receive securely
  • Ensuring that we account for donations and funding
  • Ensure that we use funding in accordance with the obligations and expectations set out in any funding agreements
  • Register your donation preferences, such as whether you want to make repeat donations, or whether you want your donation to be anonymous

Legal obligations

  • Ensuring that we process and account for any donations and funding in accordance with applicable laws, such as tax and anti-fraud / anti-corruption laws

Sharing information about you and your background & achievements and/or any donation that you have made to Echoing Green

  1. Identity
  2. Contact
  3. Profile
  4. Financial

Contract

  • To fulfill our requirements of any contract that we have with you to participate in one of our events

Legitimate interests

  • Getting to know Fellow candidates and supporting successful candidates to help them achieve their visions
  • Sharing information about our goals and activities

To administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  1. Identity
  2. Contact
  3. Technical
  4. Usage

Legitimate interests

  • Running our organization with minimal disruption
  • Addressing and preventing technical errors
  • Encouraging people to view the contents of our website

Legal obligations

  • Ensuring our website complies with applicable laws, such as anti-fraud and data privacy laws

To secure your attendance at any of our events that you wish to attend, and process personal data that you may provide us when you interact with us at an event

  1. Identity
  2. Contact
  3. Financial
  4. Profile
  5. Marketing and Communications Data

Contract

  • To fulfill our requirements of any contract that we have with you to participate in one of our events

Legitimate interests

  • Ensuring that we suitably plan, prepare and manage our events
  • Responding to a communication or request from you at any event, including by sending you any further information that you may request
  • Processing a payment that you make to us in connection with any event
  • Widening our network and getting to know you

To obtain services from you

  1. Identity
  2. Contact
  3. Financial
  4. Profile

Contract

  • To fulfill our requirements of any contract that we have with you to provide services to us

Legitimate interests

  • Managing our accounts
  • Arranging payment for your services
  • Discussing the services that you provide to us

When legally required, to respond to requests from public, governmental and regulatory authorities, comply with court orders, litigation procedures, and other legal processes

All

Necessary to comply with legally required obligations we may have under applicable laws

Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard-drive for record-keeping purposes.

Echoing Green uses cookies on its website for the following reasons:

  • Functionality/Performance cookies: These cookies are necessary for the proper operation of our website. They enable you to use secure areas of our website or make an online donation, and remember some browser plug-in preferences
  • Analytical cookies: These cookies allow us to recognize and count the number of visitors and to see how, and for how long, visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You may modify your browser preference to provide you with choices relating to cookies. You have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies you may be unable to use some Echoing Green services.

Cross-site tracking

We do not track your personal online activity on any other websites. We do not authorize third parties to use the Echoing Green website to collect personal information or track your personal online activity on our or any other website.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for their own marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Change of purpose

We will only use your personal data 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 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4. How We May Disclose Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the first table in section 4 above.

  • Service providers, acting as processors, based inside or outside the United States who provide IT / system administration and payment processing purposes.
  • Professional advisers, acting as processors, including bankers, auditors and insurers based in the United States who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities acting as processors based in the United States who may require reporting of processing activities in certain circumstances.
  • Market researchers, evaluators, judges, event partners, research organizations, based inside or outside of the US
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Please contact us if you would like any further information about any of the potential recipients of your personal data that we have described above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. How We May Transfer Your Personal Data Internationally

Any personal data that you submit on our website will be received directly by us in the United States.

If you are based in the EU (or UK following a departure of the UK from the EU) we will comply with the requirements of applicable data protection laws in respect to any transfer of your personal data outside of the EU/UK, and any subsequent transfers.

6. Our Data Security Practices

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. We permit them to process your personal data only in accordance with our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Our Data Retention Policy

How long will you use my personal data?

We will retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

8. Your Legal Rights

If you reside in the EU, you may have the following rights in respect to the personal data that you provide to us, to the extent permitted by the applicable data protection law:

  1. To withdraw any consent that you have provided to us to process your personal data.
  2. To access or rectify your personal data.
  3. To have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you consider it has been unlawfully processed.
  4. To have the processing of your personal data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it.
  5. To have your personal data transferred to another company under certain circumstances.
  6. To complain to your national data protection regulator if you feel that your personal data has been unlawfully processed.

If you want more information on any of these rights, please contact us here using the category “Privacy.”