Privacy Policy

Last Revised: September 2023

This privacy policy (the “Privacy Policy”) is intended to inform you of the policies and procedures of AFEW international; (“AFEW International,” “we,” or “us”) and its affiliates. We take the privacy and protection of your Personal Information (as defined below) very seriously. We may collect Personal Information from you in accordance with the terms of this Privacy Policy when you visit websites operated by AFEW International (the “Websites”). We are committed to protecting the privacy of visitors to our site.

This Privacy Policy is intended to inform the general public and users about the types of data we collect and how we collect it, as well as how we use, process, and disclose your information, including personal data, in conjunction with your access to and use of the Websites. Generally, if we process personal data, we will ensure that there is a legal basis for such processing. Processing of Personal Data shall comply with all data protection regulations applicable to AFEW International, including but not limited to General Data Protection Regulation (“GDPR”).

Table of contents

• Definitions
• Visitor consent
• General security
• Personal information we collect
• Data you submit about third parties
• Information we collect via technology
• Use of information we collect
• Your choices regarding personal information
• Disclosing information to third parties
• Links to outside websites
• Regarding minors
• Contact us
• Privacy policy updates

Definitions

“Account” means an AFEW International account.

“Anonymous Information” means information not associated with or linked to an individual or their Personal Information; Anonymous Information does not permit the identification of individuals.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

“ED Request” means a request for an equivalency determination.

“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Process” or “Processing” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Services” means the services we offer through the Websites. If you see an undefined term in this Privacy Policy, it has the same definition as in our Terms of Use or the terms used by in the GDPR.

General security

AFEW International takes commercially reasonable physical, electronic, and managerial precautions to prevent the loss and misuse of Personal Information under our control. Web-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, you are free to transfer Personal Information to us via alternative means, e.g. by telephone.

Personal Information we collect from our subscribers and members of the community 

There are two general categories of information we collect. In both instances, we only collect and use your information to provide the Services (e.g., for fulfilling an ED request, for getting our newsletter, for informing you about educational programs, updates in the field, and updates to the Services).

1. Information you give that is necessary for the Services (required)

We require and collect the following Personal Information that you voluntarily submit to us when you use the Websites and Services. This information is necessary for the performance of a contract to which you are a party and to allow us to comply with our (legal) obligations under the contract and more generally. The following information is required because without it, we may not be able to provide you with all the requested services:

• Account Information. When you sign up for an Account, we require certain information such as your first name, last name, email address, the password you choose, etc.
• Payment Information. We may require you to provide us with certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
• Communications with AFEW International regarding the Services. When you communicate with AFEW International to provide additional contacts, or other information needed to fulfill an ED request or payment processing, for example, we collect information about your communication (such as your email address) and any information you choose to provide in order to provide the Services.If you wish to use the Services, we require the aforementioned information; if you do not want to provide this information, you should not use the Services.

2. Information you to choose to give (optional)

• When you enter any information, including Personal Information, into any posting or comments within the Services, we will collect such information;
• When you respond to one of our surveys, we will collect any information contained in such survey responses; and
• When you leave us feedback or request support, we will collect any information that is contained in your feedback or support request (including your email address).

Data you submit about third parties
If you choose to refer a NGO entity to us, you will provide information about such third party through the Services, such as the third party’s name and email address. If the third party registers with us, such third party will become a user of the Services and subject to the terms and conditions of this Privacy Policy. If the third party does not register for the Services, we will delete any Personal Information provided within a reasonable period after obtaining the information.

Information we collect via technology
When you access any part of our Websites, our web server software automatically logs information provided by your network connection and web browser software, including the Internet Protocol (IP) address of your network connection and the type of web browser and operating system that you are using. Our web server may also log the URL of the file that you are requesting, the current date and time, and the URL of the last web page requested by your web browser.

We may utilize cookies on our Websites to store your login information (if any) and your personal preferences for the Services. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them).

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to gather information relating to the usage of our websites. The information generated by cookies (including IP addresses) is transmitted to and stored on Google servers. This information may then be analyzed and compiled into reports on website activity. Google may also transfer this information to third parties where required to do so by law, or where said third parties process the information on Google’s behalf. Google will not associate any data gathered from our Websites with any other data held by Google.

You have the option of disabling or not accepting cookies by changing the preferences in your web browser and thus permanently deny the setting of cookies. If you deactivate the setting of cookies in your browser, it is possible that not all functions of our website(s) may be entirely used. For example, if you opt to disable cookies, you will still be able to access our Websites, but you may not be able to use certain features of the websites, including placing ED Requests.

Use of information we collect 

In general, we use your Personal Information to provide the Services to you, respond to requests you make, improve the Services, and offer you additional information, opportunities, and functionality. We may also use your Personal Information to provide you with updates about the Services. Finally, we may use your Personal Information in order to comply with our legal obligations. Personal Information is not used for any additional purposes, such as to profile those who access our Websites. None of the Personal Information we collect will be shared with third parties for any other purpose than included in this Privacy Policy. 1.

Providing and improving the Services, based on the performance of a contract with you or our legitimate interests, to:

• Enable you to access and use the Websites and the Services.
• Operate, protect, improve, and optimize the Services and experience, such as by performing analytics and conducting research.
• Provide customer service.
• Send you service or support messages, updates, security alerts, and account notifications.
• Send you promotional messages and other information that may be of interest to you based on your preferences (including information about NGO source or related programs).

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we will not associate such feedback with your Personal Information. We will collect any information contained in such communication and will treat any Personal Information included in such communication in accordance with this Privacy Policy. We may create Anonymous Information records from Personal Information by excluding information that makes the Personal Information personally identifiable to you. We may use this Anonymous Information to learn more about how visitors use our Websites, to analyze trends, to administer the site, to track visitor movement, and to gather general demographic information for reporting purposes.

We process this information given our legitimate interest in improving the Services and our users’ and members’ experience, and where it is necessary for the performance of the contract with you and/or a legal obligation.

2. Other purposes

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Verify or authenticate information provided by you (such as to verify your authorization to act as an agent on behalf of a nonprofit organization).
• Conduct checks against databases and other information sources, to the extent permitted by applicable laws.
• Resolve any disputes with any of our users or customers and enforce our agreements with third parties.
• Enforce our Terms of Use and other policies.

We process this information based on our legitimate interest, the performance of a contract with you and legal obligations applicable to us to protect the Websites, to measure the adequate performance of our contract with you, and to comply with applicable laws.

Your choices regarding your Personal Information

AFEW International regularly sends newsletters and promotional communications to (a) let you know about new features or changes to our Services, (b) offer you opportunities to participate in special promotions, events, and surveys, and (c) notify you about services offered by outside partner organizations. These emails will originate from AFEW International or its affiliates. You may choose to receive such communications by subscribing to our newsletter. If at any time you no longer want to receive our newsletter, you can opt-out by following the unsubscribe instructions provided in the communication or by editing your communication preferences in your Account.

You may also occasionally receive administrative site and service announcement updates via email (such as, but not limited to, notice that we have changed the Services or the Privacy Policy) when we believe necessary. You cannot opt-out from these announcements (which are not promotional in nature), as they contain important information about changes to our Services. If you do not wish to receive these announcements, you have the option to cancel your organization’s AFEW International membership or remove yourself as a contact for your organization’s AFEW International membership. You understand that any such termination of your Account information may involve deletion of your Personal Information from our live databases. We will not have any liability whatsoever to you for any termination of your Account or related deletion of your information.

Disclosing information to third parties

1.Service providers

Since AFEW International is part of a global network, it conducts activities globally. In doing so AFEW International uses a variety of third parties to help us provide the Service. Service providers may be located inside or outside of the European Economic Area (“EEA”). The EEA unites the EU Member States and the three EEA EFTA States (Iceland, Liechtenstein, and Norway) into a market governed by the same basic rules (such as GDPR).

For example, service providers may help us: (a) verify your identity or authenticate your identification documents, (b) check information against public databases, (c) conduct background or police checks, fraud prevention, and risk assessment, (d) perform product development, maintenance and debugging, (e) allow the provision of the Services through third party platforms and software tools (e.g., through the integration with our APIs), or (f) provide customer service, advertising, or payment services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

If AFEW International may need to share your information, including Personal Information, with a service provider, in order to ensure the adequate performance of our contract with you.

2. Business transfers

If AFEW International undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence) on the basis of our legitimate interests.

3. Compliance with law, responding to legal requests, preventing harm and protection of our rights

AFEW International may disclose your information, including Personal Information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (a) comply with our legal obligations, (b) to comply with legal process and to respond to claims asserted against AFEW International, (c) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (d) to enforce and administer our Terms of Use or other agreements with our users and customers, or (e) to protect the rights, property or personal safety of AFEW International, its employees, its users, customers or members of the public.

4. Aggregated data

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, insights about the sector, demographic profiling, marketing and advertising, and other business purposes. We may share this aggregated data with the public.

Links to outside websites

This Privacy Policy applies solely to information collected through the Websites. Our Websites may contain links to outside websites for your convenience, and such links do not signify our endorsement of such websites or their contents. AFEW International has no control over, does not review and is not responsible for the privacy practices of or content displayed on other websites. We encourage our visitors to be aware when they leave our Websites and to read the privacy policies of each and every third party website that collects information from you.

Regarding minors

The Websites are not designed for minors under the age of 18. We do not intentionally gather Personal Information about visitors who are under the age of 18.

Your rights

You may exercise any of the rights described in this section by sending an email to info@afew.org. Please note that we may ask you to verify your identity before taking further action on your request.

1. Managing your information.
You may access and update some of your information through your Account settings. You are responsible for keeping your personal information up-to-date.

2. Rectification of inaccurate or incomplete information.
You have the right to ask us to correct inaccurate or incomplete Personal Information concerning you.

3. Data access and portability.
In some jurisdictions, applicable law may entitle you to request copies of your Personal Information held by us. You may also be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

4. Data retention and erasure
We generally retain your Personal Information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your Personal Information to provide the Services to you, you can request that we erase your Personal Information and close your Account. Please note that if you request the erasure of your Personal Information:

• We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user or customer from opening a new Account in the future.
• We may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, AFEW International may keep some of your information for tax, legal reporting and auditing obligations.
• Information you have shared with us may continue to be publicly visible on the Websites, even after your Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Websites to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.

5. Withdrawing consent and restriction of processing

Where you have expressly provided your consent to the processing of your Personal Information by AFEW International you may withdraw your consent at any time by changing your Account settings or by sending a communication to AFEW International specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions,
applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where (a) you contest the accuracy of your Personal Information; (b) the processing is unlawful and you oppose the erasure of your Personal Information; (c) we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (d) you have objected to the processing (see below) and pending the verification whether the legitimate grounds of AFEW International override your own.

6. Objection to processing 

In some jurisdictions, applicable law may permit you to legally object to AFEW International’s processing. In these instances, you may require AFEW International not to process your Personal Information for specific purposes (including profiling) where such processing is based on our legitimate interest. If you object to such processing, AFEW International will no longer process your Personal Information for these purposes unless we can demonstrate a legal basis for doing so or such processing is required for the establishment, exercise or defense of legal claims. At any time, regardless of applicable law, you may object to us processing your Personal Information for direct marketing purposes. You may, at any time, ask AFEW International to cease processing your data for these direct marketing purposes by sending an email to info@afew.org.

7. Lodging Complaints.

With respect to GDPR, you have the right to submit complaints about the data processing activities carried out by AFEW International before a supervisory authority; for complaints unrelated to GDPR, nothing in this Privacy Policy is intended to limit your right to file a complaint in the appropriate jurisdiction.

Operating globally

To facilitate our global operations AFEW International may transfer, store, and process your information within our family of public benefit organizations in countries both in/out of EEA. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer, store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. If you wish to receive moreinformation about the safeguards implemented by  us, please reach out to us by sending an email to info@afew.org.

Privacy Policy updates

This Privacy Policy is subject to periodic occasional revision. If we make material changes to this Privacy Policy, we will notify you through this Website or, if you have provided your email address, by email. You agree that such amended Privacy Policy will be effective thirty (30) days after being posted or sent to you, and your continued access to the Websites or use of the Services after such time shall constitute your acceptance of the amended Privacy Policy.

AFEW International
Van Diemenstraat 48, 1013 NH Amsterdam.
www.afew.org