Politique de confidentialité

CLEAN UP THE WORLD PRIVACY POLICY

CLEAN UP THE WORLD PRIVACY POLICY

Last Modified 27/07/2018

Introduction

This Privacy Policy sets out Clean Up The World's ("us" or "we") practices with respect to information collected from users who access our website at www.cleanuptheworld.org ("Site"), or otherwise share personal information with us (collectively: "Users").
Clean Up the World is the global outreach campaign of Clean Up Australia Limited ABN 93 003 884 991, a not-for- profit organisation registered in Australia, whose mission is to clean up, fix up and conserve the environment.

We respect and seek to preserve the privacy of our users and this Privacy Policy will help you to understand how we collect, use and safeguard your personal information. The kind of information we may collect from or about you will depend on your relationship with us (e.g. as a donor, volunteer, employee, customer, or online user of our Site).

Relevant Law

Any data provided to us is subject to the Privacy Act 1988 (Cth) ("Privacy Act"), or if you are located in the European Union, the European Data Protection Regulations ("GDPR"). 

Dealing with Clean Up the World Anonymously

You may deal with us anonymously however in certain situations we will request your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter "Personal Information") because it is required by law or because it would be impracticable to deal with you anonymously. These situations include where you have purchased products from our online store, made donations to us, requested we contact you using your details or when you submit a request, enquiry or complaint.

Grounds for data collection

The 'Processing' (defined in the GDPR from time to time as: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction) of your Personal Information is necessary for:
1. the performance of our contractual obligations towards you and providing you with our goods or services;
2. the protection of our legitimate interests; and 
3. compliance with legal and financial regulatory obligations to which we are subject.

Your Consent to data collection

When you use the Site, you consent to the Processing of your Personal Information as described in this Privacy Policy. We may request additional consents from you from time to time depending on your use of the Site and the goods or services you may choose to use or purchase.

You may withdraw your consent in writing by using the contact details below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

What information do we collect?

We process two types of data and information from Users:

1) un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via their use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include aggregated usage information and technical information transmitted by a User's device, including certain software and hardware information (e.g. the type of browser and operating system used, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on a User's activity on our Site (e.g. pages viewed, online browsing, clicks, actions, etc.); and

2) Personal Information, such as: your full name, job/position title, employer or organisation which you may represent, your home or work address, telephone number; email address, payment information, transaction information; your Internet Protocol ("IP") address, server address, domain name and information on browsing activity when visiting one of our webpages. We may also collect other specific information from you relating to and in order to provide any goods or services you wish to obtain or donations or contributions you may wish to make.

How we use your information

We will use the personal information we collect for the purpose disclosed at the time of collection or otherwise as set out in this Privacy Policy. We will not use your personal information for any other purpose without first seeking your consent, unless authorised or required by law. 

Generally we will only use and disclose your personal information for:

1) providing you with products and or services requested; 
2) dealing with requests, enquiries, complaints, returns (including consumer guarantees and or warranty claims); 
3) payment processing (including purchases or donations); 
4) establishing and maintaining your relationship as a supporter of us and our environmental causes, including providing you with newsletters, reports and other information;
5) assisting you with your involvement in a our campaigns; 
6) providing the services you have requested from CUW or to answer your inquiry; 
7) sending you newsletters or other current information; 
8) registering you for events or promotions; 
9) assisting us to make CUW's services more valuable to our supporters and members; 
10) for direct marketing of products or services and to keep you informed of new developments we believe may be of interest to you. If we contact you in this way without obtaining your prior consent, we will provide you with the opportunity to decline any further marketing communications; 
11) enabling our third party providers to assist us in providing the Site and any goods or services to you (such as our emails and newsletters, webhosting and information systems); and 
12) reporting to any government, regulatory or other funding body regarding how funding and or donations are used;
13) carrying out any activity in connection with any legal, governmental or regulatory requirement that we must comply with or in connection with any legal proceedings, crime or fraud prevention, detection or prosecution, where otherwise legally permitted or required by law.

How do we receive information about you?

We receive your Personal Information from various sources:

- When you voluntarily provide us your personal details in order to register on our Site; 
- When you use or access our Site in connection with your use of our services; and,
- From third party providers, services and public registers (for example, traffic analytics vendors).

What happens if we cannot collect this information?

If we cannot collect or use the information set out above (depending on your use of the Site) then we may not be able to: process any donations, enable your participation in any of our activities, provide you with any services or information, or provide you with direct marketing. 

How we share your information

We will not rent, sell, or share your information with third parties except as described in this Privacy Policy.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our third party service providers, who may be located in different jurisdictions across the world, for any of the following purposes:

- Hosting and operating our Site; 
- Billing and transaction management;
- Providing you with our services, including providing a personalized display of our Site; Storing and processing such information on our behalf; 
- Providing you with marketing offers and promotional materials related to our Site and services (including material delivered by email); and
- Performing research, technical diagnostics or analytics.

These third-party service providers enter into a contract with us that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this privacy policy.

Our third party service providers include:
1. Made With Ed Pty. Ltd. (trading as Funraisin) – For our webhosting and financial transactions (including donations)
Privacy Policy and Contact Details
2. The Rocket Science Group LLC (trading as MailChimp) – For our marketing, promotional and email campaigns
Privacy Policy and Contact Details
3. Stripe Payments Australia Pty Ltd – To facilitate any financial transactions between you and us (such as making donations)
Privacy Policy and Contact Details


We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: 

(i) comply with any applicable law, regulation, legal process or governmental request; 
(ii) enforce our policies (including any contracts or agreements), including investigations of potential violations thereof; 
(iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; 
(iv) to establish or exercise our rights to defend against legal claims; 
(v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or 
(vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

User Rights

You may make a written request to us in order to:

▪ Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
▪ Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
▪ Request rectification of your personal information that is in our control.
▪ Request erasure of your personal information.
▪ Object to the processing of personal information by us.
▪ Request to restrict processing of your personal information by us.
▪ Lodge a complaint with a supervisory authority.
▪ Withdraw your consent to any collection or use which you have previously consented to.

If you wish to change personal information that is out of date or inaccurate at any time please contact us in writing using the email details below. After notice from you, we will take reasonable steps to correct any of your information that is inaccurate, incomplete or out of date. If you wish to have your personal information deleted please let us know and we will delete that information wherever practicable.

We may refuse your request to access, amend or delete your personal information in certain circumstances. If we do refuse your request, we will provide you with a reason for our decision and, in the case of amendment, we will note with your personal information that you have disputed its accuracy.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us in writing using the email details below.

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. For example, to satisfy our obligations under Australian Taxation laws we will keep a record of donations for up to 7 years.
 Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. 

Under applicable regulations, we will keep records containing client personal data, account and transaction documents (including payment details), communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

How do we safeguard your information?

We will take all reasonable steps to ensure the security of the personal data we hold from such risks as loss or unauthorized access, destruction, use, modification or disclosure of data. We generally store the personal data we hold in electronic databases; some of which may be held on our behalf by third party service providers.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

- 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
- 'persistent cookies' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
- 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

Google Analytics

We also use Google Analytics (a product of Google LLC) to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We only use the information we receive from Google Analytics to improve our Site and services. Google Analytics collects your IP address on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. 

Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and Google's Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.


International Transfer of data 

The European Commission has determined that certain countries outside of the European Economic Area (EEA) adequately protect personal data ("Adequacy Decisions"). A list of Adequacy Decisions can be found here. 

In the absence of an Adequacy Decision, we will only transfer your personal information outside the EEA where:

1. you have purchased goods or services from us and the transfer of your personal information is necessary for the performance of this contract between us; or
2. we have obtained your consent.

If you reside within the EEA; when giving us your consent to transfer your data outside of the EEA you should be aware of the following:

1. Your personal data will be transferred to Australia;
2. Australia may not be subject to an Adequacy Decision;
3. The Australian Privacy Act 1988 (through what is known as the Australian Privacy Principles) will provide protections for your data however these are different to your data's protections under the GDPR. For example, you may not have the same data rights such as the right to erasure; and
4. We may share your personal data (depending on your use of this Site) with your third-party service providers listed above.
Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services (such as events and activities we organise or assist in organising), which we believe may interest you.

We will provide you within such marketing materials the means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us in writing using the email details below.

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us or make a complaint

If you have any general questions or complaints about the Site or the way CUW collects, holds, uses or discloses your Personal Information please detail your question or complaint in writing to:

Clean Up Australia Limited
Attn: Privacy Officer – Clean Up the World
Email: world@cleanup.com.au
Mail: 193 Darlinghurst Rd
Darlinghurst NSW 2010 Australia


Last Modified 27/07/2018



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