ASYLOS WEBSITE PRIVACY POLICY

Asylos is committed to protect the privacy of personally identifiable information collected from the web site (including mobile web sites and apps) owned and controlled by Asylos (the “Asylos Site”).

1. Who we are

References to “we”, “our” or “us” in this Privacy Policy mean Asylos, a charity registered under the laws of the UK, having its registered offices at Unit 12 Imperial Works, Fountayne Road, South Tottenham, London N15 4QL United Kingdom (“Asylos”).

For the purposes of data protection laws, we are the “Data Controller” in respect of the personal data provided on the websites https://asylos.eu/ and https://resources.asylos.eu.

2. Scope and Content

This Privacy Policy explains how we collect, store, use and disclose information, including your Personal Data (as defined hereafter), collected through Asylos Sites. By using Asylos Sites, you agree with Asylos's collection, use, storage and disclosure of your Personal Data in accordance with this Privacy Policy. This Privacy Policy is incorporated into and made a part of Asylos Site Terms of Use.

For the purpose of this Privacy Policy, “Personal Data” is any information relating to an identified living person or a living person who can be identified, directly or indirectly, by means reasonably likely to be used by Asylos, in particular by reference to an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

3. Personal Data We Collect

Asylos may collect, store and use various types of Personal Data, such as:

• information about your computer, your visits and use of Asylos Sites (including IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths) and more generally information collected through cookies and similar technologies;
• information provided when registering and completing profile details (such as, but not limited to, salutation, first and last name, email address, title or function, phone number, employment or company details, country and other location details, category (e.g. lawyer, NGO, volunteer);
• your subscription choices for Asylos email notifications, alerts and/or newsletters;
• information provided when using the services on Asylos Sites, or that is generated in the course of the use of those services (such as the timing, frequency and pattern of service use);
• information relating to any donations you make to Asylos
• information that you post on Asylos Sites (user name, profile pictures and the content of your posts);
• information sent to Asylos through Asylos Sites or otherwise (including the communication content and metadata associated with the communication), e.g. when you make a research request through our online form on the Asylos Resources Site;

• any other Personal Data communicated by you to Asylos.

Such Personal Data may be collected from:

• you directly, when you use Asylos Sites, sign up for a newsletter or contact us; or
• other sources, such as public databases, joint partners, and social media platforms (e.g. for data such as organisation name, location, job title).

To the extent you submit any Personal Data about other people to Asylos, you represent that you have the authority to do so and to permit Asylos to use such third party Personal Data in accordance with this Privacy Policy.

4. Our use of your Personal Data

Asylos may use your Personal Data for the following purposes:

• administer and personalise Asylos Sites for you by presenting products, marketing messages, and content tailored to you;
• provide you with information, services made available by Asylos;
• complete and fulfil donations done through Asylos Sites or otherwise and execute transactions (send statements, process payments, orders, invoicing and overall manage your accounts);
• send you non-marketing commercial communications;
• share your Personal Data with other Asylos affiliates where appropriate to offer you a better service;
• send you email notifications that you have specifically requested, respond to your inquiries and fulfil your requests, such as to send you research reports;
• send you marketing communications relating to Asylos and selected third party businesses that Asylos believes may be of interest to you, such as newsletters, in accordance with your communication preferences (you can inform us at any time if you no longer wish to receive newsletter or marketing communications);
• deal with enquiries and complaints made by or about you relating to any Asylos Site;
• perform data analysis, audits, crime/fraud monitoring and prevention, security, improving or modifying Asylos Site;
• identify usage trends, determining the effectiveness of promotional campaigns, operating and expanding Asylos’s activities;
• associate information you provide us, with other information we collect from you or about you from third parties, for analytics purposes and to improve our services; and
• check compliance with the terms and conditions governing the use of Asylos Sites.

Donations are handled through Asylos payment services providers. You can review the providers’ privacy policies on their respective websites. Asylos will share information with Asylos payment services provider only to the extent necessary for the purposes of processing payments you make via the Asylos Sites, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

Your Personal Data are processed on the basis of at least one legitimate ground which may be, depending on the categories of Personal Data and the purposes of the processing: (i) your explicit consent (which may be withdrawn at any time), (ii) the performance of a contract with you or pre-contractual steps for a contract with you, (iii) compliance with our legal obligations or (iv) our legitimate interest (such as in running our business effectively and in improving the quality of our products and services) or the legitimate interest of the third parties to whom we transfer your Personal Data.

5. Disclosure of Your Personal Data to Third Parties

Asylos may share your Personal Data with its subsidiaries and any of Asylos’s employees, officers, insurers, professional advisers, agents, suppliers or subcontractors around the world for the purposes described in this Privacy Policy. Asylos may also share your Personal Data with third-party suppliers and service providers worldwide for data processing, storage, and other services such as web site hosting, data analysis, order fulfillment and delivery, information technology and related infrastructure provision, customer service, email delivery, credit card and payment processing, auditing and other similar services.

Furthermore Asylos may share your Personal Data with a third party worldwide in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Asylos Charitable Incorporated Organisation (CIO) (including in connection with any bankruptcy or similar proceedings).

Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

1. Your data will be made available to our website provider
2. The data that may be available to them include any of the data we collect as described in this privacy policy.
3. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
4. They will store your data for a maximum of 7 years.
5. This processing does not affect your rights as detailed in this privacy policy.

Asylos will also share or release information, including Personal Data, if (i) Asylos has your permission to make the disclosure, (ii) when Asylos believes release is appropriate or required to comply with the applicable laws and/or to respond to requests from competent public and government authorities including public and government authorities outside your country of residence, (iii) in connection with any ongoing or prospective legal proceedings, (iv) enforce or apply Asylos Terms of Use and other policies or agreements, or (v) protect the rights, property or safety of Asylos and other users (including for fraud protection).

6. Marketing Preferences

When you visit the Asylos Sites, register for an online account with Asylos or enter or make donations through the Asylos Site, subscribe to a newsletter, or enter a contest or other promotion, you may receive marketing communications from Asylos (subject to your consent, where applicable). If you receive these marketing communications, you may unsubscribe from those marketing communications at any time. Email messages will contain instructions on how to “unsubscribe” from receiving such marketing communications.

You are always free to update your communication preferences for the marketing activities performed by Asylos. Thus you may accept or refuse receiving marketing-related messages from Asylos in the future or update your communication preferences by following the instructions included in each marketing-related message. 

Asylos shall comply with your request as soon as reasonably practicable. Please also note however that Asylos may still send you important administrative and transactional messages (i.e. service notifications) in connection with a transaction, your research request, or information about your account.

7. Retention of your Personal Data

Asylos will retain Personal Data for a maximum of three (3) years after your unsubscribe, unless a longer retention period is required to fulfill the purposes outlined in this Privacy Policy and permitted by law.

Asylos will also retain Personal Data: (i) to the extent that Asylos is required to do so by law (e.g. for tax purposes), or (ii) the Personal Data may be relevant to any ongoing or prospective legal proceedings, or (iii) in order to establish, exercise or defend Asylos’s rights (including providing information to others for the purposes of fraud prevention).

8. Our Use of Cookies

Asylos uses cookies and other tracking technologies online. Please read the Asylos Cookies Policy, which is part of this Privacy Policy, and is incorporated herein by reference.

9. Your Rights in Relation to your Personal Data

You have certain rights under applicable data privacy laws in relation to your Personal Data, including rights to, in certain circumstances:

• request access to the Personal Data Asylos holds about you and be provided information in relation to that Personal Data (including the purposes for which it is processed, the recipients to whom that personal data has been or will be disclosed, how long it will be stored for, details of any automated decision-making and your right to lodge a complaint with a supervisor authority);
• request that Asylos amends inaccurate Personal Data about you, and to have incomplete Personal Data completed;
• request the erasure of the Personal Data Asylos holds about you, for example where it is no longer necessary for Asylos to hold the information;
• object to or restrict Asylos’s processing of your Personal Data (including processing for direct marketing purposes). This includes the right to opt-out of receiving further marketing emails;
• request that Asylos provides you with an electronic copy of the Personal Data we hold about you. To the extent it is technically feasible, Asylos can also transmit your Personal Data to another data controller;
• object to any decision affecting you that has been taken solely by a computer or other automated process; and
• contact the data protection supervisory authority of your country if you have any concern about the use of your Personal Data.

To exercise any of these rights, you may use the contact email address detailed in Section 17 of this Privacy Policy. Asylos will handle your request as soon as reasonably practicable, in accordance with applicable laws.

Asylos may need to retain certain information for back-up and record-keeping purposes, as required under applicable legal obligations, and/or to complete any transactions that you agreed prior to requesting such change or deletion (e.g. when you make a donation, you may not be able to change or delete the Personal Data provided until after the completion of such donation).

10. International Transfers of Your Personal Data

Asylos may transfer your Personal Data to any Asylos group charity worldwide when processing, storing and using information for the purposes described in this Privacy Policy. Asylos may also transfer Personal Data to its third party service providers located in a different country or territory to the one you are located in. Asylos may therefore transfer your Personal Data to territories outside the European Economic Area (the “EEA”) to countries which do not have data protection laws equivalent to those in force in the EEA, such as the United States of America.

To the extent your Personal Data would be transferred to a country or territory outside the EEA that does not ensure an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of Personal Data, we have in place requirements relating to such international data transfers. For example data processing agreements.

Furthermore, Personal Data that you post or submit for publication on the Asylos Sites may be available, via the internet, around the world. Asylos cannot prevent the use or misuse of such information by others.

11. Security of Your Personal Data

Asylos pays attention to the security of your Personal Data, and therefore Asylos uses various security technologies to protect it, including secure servers, firewalls and encrypted solutions and reasonable and appropriate organizational, technical, and administrative measures  to protect Personal Data within Asylos against unauthorized or unlawful access, alteration, disclosure or destruction.

However, transmissions over the internet are never entirely secure or error-free and Asylos does not guarantee the security of the information communicated to and/or from Asylos Sites. It is your responsibility to safeguard any password, user ID and other Personal Data while using Asylos Sites.

12. Minors and children under the age of 13

The Asylos Sites are not directed at, and are not intended for minors and children under the age of thirteen (13). Asylos will not knowingly collect data from children without proper parental consent. If you believe that Asylos may have collected Personal Data from someone under the age of thirteen (13), or under the applicable age of consent in your country, without parental consent, you can contact Asylos to take appropriate measures to investigate and address the issue promptly. Parents wishing to access, review or delete their child’s Personal Data may contact Asylos by using the contact email address detailed in Section 17 of this Privacy Policy.

14. Social Computing

Asylos may provide social computing tools to enable online sharing and collaboration among registered users. These include forums, wikis, blogs, instant messaging, open-source development and other social media platforms. When registering to use certain social computing tools on Asylos Sites, you may be asked to provide certain Personal Data. Such Personal Data and other information collected during the registration on Asylos Sites will be subject to this Privacy Policy, except Personal Data and other information that you make publicly available or you communicate to other participants. These tools may also include supplemental terms of use and may include additional privacy notices. 

15. Third party websites

The Asylos Sites may include hyperlinks to third party websites. Asylos has no control over such third party websites and their practices and is not responsible for the policies and practices of such third party websites. This Privacy Policy does not address the policies and practices of such third parties related to privacy and security, data collection, processing, use, storage, and disclosure of Personal Data.

16. Changes to this Privacy Policy

This Privacy Policy supersedes all previous versions.

Asylos reserves the right to change this Privacy Policy at any time. Any change to this Privacy Policy will become effective when Asylos makes the revised Privacy Policy available on Asylos Sites or when Asylos notifies you of such change.

17. Contact

You can contact Asylos regarding this Privacy Policy at the following email address: [email protected]. Please provide Asylos with your contact details, the name of the Asylos Site or service in question, and a detailed description of your request.  

Effective Date: 1 January 2019