1. PURPOSE
This privacy policy has been compiled to better serve those concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact or locate a single person or to identify an individual in context. Please read our privacy policy carefully to understand how we collect, use, protect or otherwise handle your Personally Identifiable Information per our website.
THINK EQUAL is a charity registered as a 501c3 in the USA, incorporated under the laws of Delaware. It is also a charity registered in England and Wales, number 10166996. Think Equal in the UK is registered with the UK Information Commissioner’s Officer under reference ZA320513.
We may update this Privacy Policy [“the Policy”] from time to time, so please check back regularly. We will notify you of any significant changes by placing a notice on our website. By contacting us or visiting our website, you agree to be bound by the Policy. If you have any queries about the Policy, please get in touch with us at contact@thinkequal.org.
2. INFORMATION COLLECTED
We collect information from you when you register on our site, mak a donation, subscribe to a newsletter, fill out a form or enter information on our site.
The personal information we collect may include details such as your name, date of birth, email address, postal address, telephone number and credit/debit card details, as well as information you provide in any communication between us. You will have given us this information yourself while making a donation, registering on our online training platform, enquiring about our work, communicating with us on social media or any of the other ways you interact with us.
We will mainly use this information:
- To process your donation or other payments, to claim Gift Aid on your donations (in the UK if applicable) and verify any financial transactions;
- To provide the information or services (including about our Social and Emotional Learning Programme for schools) that you have requested;
- To update you with any important administrative messages about your donation, information or services you have requested;
- Within the UK (if applicable), to comply with the UK Charities Protection and Social Investment Act 2016 and follow the recommendations of the official regulators of charities, the UK Charity Commission, which requires us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations;
- To keep records of our relationship with you;
- To contact you about our work and how you can support us;
- Where you volunteer with us to administer the volunteering arrangement.
We will never sell your data to any third party or share your details with other entities for marketing purposes.
Protection
We are committed to keeping your personal information safe and secure and comply with Delaware’s privacy protection law – Code § 1204C and Tit. 6 § 205C. Also, we’ve implemented appropriate physical, technical and organisational measures to protect the personal information under our control. We work hard to ensure that the information we receive is kept secure, accurate, up-to-date, and only for as long as necessary for the purposes for which it is used.
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters, submits or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
However, the transmission of data over the internet is never 100% secure, so while we try to protect your personal information, we can’t guarantee the security of any information you submit to us via our website.
Legal Compliance
THINK EQUAL may need to disclose your information if required by law or in response to a court order.
We have also implemented the following:
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously.
- Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.
- Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
You will be notified of any Privacy Policy changes:
- On our Privacy Policy Page
Can change your personal information:
- By emailing or calling us
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
- Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address to:
- Send information, respond to inquiries, and/or other requests or questions.
To be in accordance with CANSPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe using the link at the bottom of each email.
Consent
By providing us with your personal information, you consent to the collection and use of that information for the purposes and in the manner described in the Privacy Policy. We will only keep your information for as long as is reasonable and necessary for the relevant activity or to fulfil statutory obligations (for example, the collection of Gift Aid).
Links
Our website and social and emotional programme may include links to websites run by other organisations. THINK EQUAL is not responsible for the privacy practices or policies of other organisations, so you should read their privacy policies carefully.
3. YOUR RIGHTS
We will only collect the data we need to carry out the purposes you have contacted us for or permitted us to use it.
You have the right to ask for a copy of the information we hold about you and to have any inaccuracies in your information corrected. You can have your personal information removed at any time or object to the processing of your personal information. And you can withdraw your previous consent at any time as well. You can click the unsubscribe button on the footer of any of our emails if you’d like to unsubscribe from our mailing lists.
If you wish to exercise any of these rights, please contact us at contact@thinkequal.org or at 900 Foulk Road, Suite 201, Wilmington, New Castle County, Delaware 19803.
If you feel your privacy rights have been violated or that we have violated our own privacy practices, you can file a complaint with us in writing using the contact information shared above.
Last Updated: May 2024