Privacy Policy

Last Update: July 7, 2020

Introduction

This privacy policy (“PrivacyPolicy”) describes the collection of personal information by Global Support and Development, a 501c3 organization, (“GSD”, “Company,” “we,” “us”, or “our”) from users (“you”, “your”) through your use of our website at https://gsd.ngo/ (our “Site”). This Privacy Policy also describes our use and disclosure of such information.

This Privacy Policy also describes your rights as a data subject to inquire about your personal information that we process and describes certain rights that you, as the data subject, have regarding this information.

For the purposes of EU and United Kingdom data protection laws (“Data Protection Legislation”), GSD is a data controller (i.e., the company that is responsible for and controls the processing of your personal information).

Please read this Privacy Policy carefully to understand our practices regarding your personal information and how we will use it. By accepting this Privacy Policy you agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy.

Contacting us

If you have any questions or comments about this Privacy Policy, please contact us using the following contact information:

Global Support and Development
455 C St
Washougal, WA 98671
United States
privacy@gsd.ngo

What information do we collect?

We use your personal information to carry out the obligations arising from providing, operating, and improving the Site. This section describes the types and categories of personal information we may collect, and how we may use that information.

Information you provide us directly

We collect personal information that you provide when you enter your information into online forms, such as the ‘contact’ page or otherwise use the Site. We use this personal information in the following ways:

• When you use the ‘contact’ form on our website, we may collect your first and last name, and your email address;
• Additionally, when you use the contact form on our website, you will have the opportunity to enter a message. We ask that you do not provide sensitive, confidential or otherwise personal information when you do this.

Automatically collected information

When you use our Site, some information is collected automatically and is not provided directly by you. For example, when you access our Site, we automatically collect your browser’s Internet Protocol (IP) address, your browser type, the nature of the device from which you are visiting the Site (e.g., a personal computer or a mobile device), the identifier for any handheld or mobile device that you may be using, the web site that you visited immediately prior to accessing our Site, the actions you take on our Site, and the content, features, and activities that you access and participate in on our Site. We also may collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message.

Cookies and Similar Technologies

The Site uses cookies and similar technologies to distinguish you from other users of the Site and allows us to better understand your usage of the Site. For more information, please refer to our cookie policy at Cookie Policy.

Collection and processing of sensitive information

The Site does not collect or process ‘sensitive information’ defined as data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. As such, you should not provide any such information as part of any correspondence, or by any other means with your use of the Site.

How do we use personal information?

We use your personal information for the following purposes:

• When you communicate with us using one of the methods described in this Privacy Policy, we may also keep a record of the time and date of any correspondence, and also organize this correspondence in one or more of an electronic filing system, an email system or a customer relationship management system;
• We may link this personal information to data about the way you use our Site and the pages you visit to help enhance, improve, operate, and maintain our Site;
• To prevent fraudulent use of our Site and other systems;
• To prevent or take action against activities that are, or may be, in violation of our standards or applicable law.

Legal basis for processing in the EU and the United Kingdom

If you are resident in the EU or the United Kingdom, we need to inform you about the legal basis on which we collect and use your personal information. In the EU and the United Kingdom, the purposes for which we process your personal information are:

• For the purposes of legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal or regulatory obligation in the EU and the United Kingdom.

The legal basis depends on the category of personal data being processed, and the purpose for that processing. The following table indicates each category of personal data we process, and the legal bases we rely on to do so. Where legitimate interest has been used as the legal basis for processing, the specific legitimate interest we use has been described. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where one or more legal bases have been indicated.

Category of Personal Data	Legal Basis for Processing
Contact information and correspondence	Our legitimate interests, namely, responding to your inquiries.
Automatically collected information	Our legitimate interests, namely, administering and understanding your usage of the Site.

When do we share personal information?

Except as described in this Privacy Policy, we will not disclose your personal information that we collect on the Site to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• Site Providers. We may disclose personal information to third-party service providers (e.g., web hosting providers, and other SaaS providers) that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such personal information.
• Business Transfers. Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
• To Protect our Interests. We also disclose personal information if we believe that doing so is legally required, or is in our interest to protect our property or other legal rights, or the rights or property of others, or otherwise to help protect the safety or security of our Site and other users of the Site.
• To Comply with the Law: We may also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Communication choices

If you receive email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving emails from us, and any other communications that we may send to you from time to time by sending your request to us by email at privacy@gsd.ngo or by writing to us at the address given in the ‘Contacting Us’ section of this Privacy Policy.

Please be aware that if you opt-out of receiving emails from us, it may take up to ten business days for us to process your opt-out request, and you may receive emails from us during that period.

Rights to access

You have the right to access and update the personal information that you have provided to us. If you wish to access or amend any other personal information we hold about you, you may contact us at privacy@gsd.ngo. If you request that we delete your information, we will do so within a reasonable period of time, but we may need to retain some of your personal information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

Links to external sites

The Site may contain links to other websites, products, or services that we do not own or operate. The Site also may contain links to Third-Party Sites such as social networking services. If you choose to visit or use any Third-Party Sites or products or services available on or through such Third-Party Sites, please be aware that this Policy will not apply to your activities or any information you disclose while using those Third-Party Sites or any products or services available on or through such Third-Party Sites. We are not responsible for the privacy practices of these Third-Party Sites or any products or services on or through them. Additionally, please be aware that the Site may contain links to websites and services that we operate but that are governed by different privacy policies. We encourage you to carefully review the privacy policies applicable to any website or service you visit other than the Site before providing any personal information on them.

How long do we keep your personal information for?

Unless otherwise specifically stated elsewhere in this Privacy Policy, we will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Aggregated and anonymized data that no longer identifies the user of the Site is maintained for the purposes necessary to provide the Site.

EU privacy rights

If you are located in the EU, you have the following Data Subject Access Rights with respect to your personal information that we hold:

• Right of access. You have the right to access the personal information that we hold about you;
• Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal information we hold about you;
• Right to erasure. In certain circumstances, you may have the right to the erasure of your personal data we hold about you (for example where it is no longer necessary in relation to the purposes for which it was collected or processed);
• Right to restriction. You may have the right to request that we restrict processing of your personal information in certain circumstances (for example where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data);
• Right to portability. In some limited circumstances, you may have the right to portability which allows you to move, copy or transfer personal data from one organization to another;
• Right to object. You have a right to object to us processing your personal information when the processing is based on legitimate interests and also to stop us from sending you direct marketing;
• Rights in relation to automated decision making and profiling. You have the right not to be subject to a decision that affects you based solely on automated processing. We do not perform any automated decision making and profiling.

If you wish to exercise one of these rights, please contact us using the information in the ‘Contacting us’ section of this Privacy Policy.

What is our policy on children?

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Site is not directed to users under the age of 13, and we do not knowingly collect personal information from children under the age of 13 without obtaining parental consent. If we learn that we have collected personal information from a child under the age of 13 on our Site, we will delete that information as quickly as possible. If you believe that we may have collected any such personal information on our Site, please notify us at privacy@gsd.ngo.

Where do we store and process your personal information?

When GSD obtains personal information about you we may process and store the information outside of the country in which you are located, including in the United States. The countries in which we process the information may not have the same data protection laws as the country in which you are located. If you are using the Site or Sites from the European Union (“EU”), the United Kingdom, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please note that you are transferring your personal data to the United States which does not have the same data protection laws as the EU, the United Kingdom, and other regions, and by providing your personal data you permit the use of your personal data for the uses identified above in accordance with the Privacy Policy.

California privacy disclosures

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes, subject to certain exceptions, as defined in California Civil Code Sec. 1798.83. In general, subject to certain exceptions, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide, free of charge, a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California Customers may request further information about our compliance with this law by sending an email to privacy@gsd.ngo

How do we secure your personal information?

To help protect your data, we use commercially reasonable steps to protect the data that we collect, including your personal information. The reasonable steps include protecting this data against accidental loss, unauthorized use, disclosure, and restricting access to personal information by our staff. The Site is hosted by a third-party hosting company that we have determined maintains adequate security controls and utilizes TLS encryption for all internet communication with the Site. We also require all staff that administer and develop the Site follow industry-standard controls, including strong passwords, the use of anti-virus and anti-malware software, disk encryption, and other best practices.

We use various 3rd party processors to enable us to provide the Site, and as part of our vendor due-diligence, we review the security controls these processors have in place and ensure they meet industry standards appropriate for the type of data we collect.

You should keep in mind, however, that the Site utilizes software, hardware, and networks, which from time to time require maintenance and experience problems beyond our control. Note that no data transmission over the public internet or encryption method can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information that you provide to us. You transmit information to us at your own risk.

Updates to this Policy

We may occasionally update this Policy. When we do, we will also revise the “last updated” date at the beginning of the Policy. Your continued use of our Site after such changes will be subject to the then-current policy. If we change this Policy in a manner that is material, we will use reasonable efforts to notify you via the contact methods you have provided of the change prior to applying the change to any personal information that we collected from you prior to the date the change becomes effective. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and disclose personal information.