Effective Date: 13 November 2019
1. About Rumi Foundation Ireland's privacy programme
1.1 Rumi Foundation Ireland has been working around the world to eradicate poverty since 2019. For over one year, we have been delivering aid and development programmes to transform the lives of communities, by educating social responsibility, supporting access to sources and creating opportunities to live peacefully.
Operating at Townhouse, st Mary square, Athlone, co. Westmeath, Ireland
1.4 “Personal data” that we process means any information that relates to a living, identifiable person, including but limited to names, physical and email addresses, internet identifiers, phone numbers, and other information relating to that person, and either individually or combined can be used to identify that person.
1.5 “Process” or “Processing” in the context of this policy mean the activities we perform on personal data, such as collection, computing, storage and disposal.
1.6 This policy applies when we are a data controller, as defined in the GDPR, with respect to the personal data of our website visitors, donors, sponsors, volunteers and aid recipients. As a data controller, we determine the purpose and means of personal data processing.
1.7 Our personal data processing is consistent with the principles outlined in the GDPR:
• We process personal data lawfully, in a way that you would reasonably expect, and we are open and clear about our personal data processing practices;
• We will only collect and process personal data that we need to and when it is necessary for processing that is required by our websites, apps and services;
• We will only collect and process personal data that is optional, such as marketing, after we receive your informed, freely given consent enabled by privacy controls on our websites, apps and services; you can opt out at any time after providing consent;
• When we do, we will be clear about why and how we are doing so, and for how long we will retain the personal data;
• We will take steps to ensure the personal data is accurate and provide means to correct inaccuracies; and
• We implement appropriate, common, technical and organisational controls to safeguard personal data for integrity and confidentiality.
2. How we use your personal data
2.1 Here we describe:
a. the general categories of personal data that we may process;
b. the source and specific categories of that data, in case we did not obtain it directly from you;
c. the purposes for which we may process personal data; and
d. the legal reasons (known as lawful bases) for processing personal data.
2.2 We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. This includes:
a. Direct Interactions: We process personal data you provide directly to us through our website, apps and services. This could happen when you:
• support our work by donating;
• inform us of your fundraising activities;
• correspond with us or make an enquiry such as a request for information from our support team regarding our projects or your sponsored projects;
• visit any of our premises which has CCTV surveillance (images on film) for security and safety purposes;
• participate in any of our events or challenges;
• apply for a job or to volunteer;
• verify your identity;
• opt into communications and/or marketing services (by providing consent); or
• contact us or become involved with us in any other way not listed above.
We process this information to provide the service or information you have requested. Our lawful basis for processing is legitimate interests.
b. Usage Data: We may process data about your use of our website and services. The usage data may include:
• IP address;
• geographical location;
• browser type and version;
• operating system;
• referral source;
• length of visit;
• page views;
• website navigation paths; or
• information about the timing, frequency and pattern of your service use.
The source of the anonymised usage data is our website. We process this information for monitoring and security purposes, and to improve our website and services. Our lawful basis for processing is legitimate interests.
c. Account and Profile Data: When you donate or set up a donor record with Rumi Foundation Ireland, we need to store some information in order to preserve your details. This includes:
• telephone number;
• email address.
We use account and profile data to:
• operate our website;
• provide our services, products or information you have requested, like water hand pump feedback reports;
• process your donations;
• providing you information about our activities and services;
• keep you updated of our fundraising campaigns and events;
• respond to your enquiries and complaints;
• sending you a receipt to confirm your donation (unless requested otherwise);
• process Gift Aid donations;
• ensure the security of our website and services;
• maintain back-ups of our databases; or
• communicate with you.
Depending upon the nature of the processing, the lawful basis for this processing is either our:
• legitimate interests (namely the proper administration of our service and charity); or
• contract performance.
d. Transaction Data: We may process information relating to transactions, including donations. The transaction data may include:
• contact details;
• your card or bank details;
• your Irish taxpayer status (for Gift Aid claims, as applicable); or
• other transaction details.
The transaction data may be processed for the purpose of recording donations, processing UK Gift Aid claims, and keeping proper records of those transactions. We do not store credit card details; these are stored securely by our processing partners. The lawful basis for this processing contracts, or in the case of Gift Aid claim, legal obligation.
e. Special Category Data: We may request and if received with your consent, process information relating to your:
• racial and ethnic status;
• passport information and date of birth;
• other identification information e.g. driving licence; or
• health information.
The special category data may be processed for the purpose of providing you with the necessary support and precautionary care during participation in activities and events, such as challenge events or international travel. Before collecting any special category data about you, we will make it clear what information we are collecting and why we need it. The lawful basis for this processing is consent.
f. Children’s Data: While we do not actively collect information from children (under 18s), we appreciate that our supporters are of all ages. Where required, we will always ask for consent from a parent or guardian to collect information about children. All Rumi Foundation Ireland events will have clear rules on whether children can take part, and the collection of data will be managed in accordance with each individual event, with appropriate safeguards.
2.3 Additionally, we may process any of your personal data identified in this policy where necessary for:
• the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The lawful basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights or the legal rights of others; or
• the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our charity against risks;
• compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. How we share your personal data
3.1 We will not sell your details to any third parties, but we may sometimes receive details from our trusted service providers who are authorised to act on our behalf and partner organisations who work on our behalf, or whom we work with in partnership to deliver our projects, such as JustGiving and Eventbrite.
3.2 We may also use companies to deliver services and process your data on our behalf, including the delivery of postal mail, sending emails and text messages, processing card or bank details and analysing stakeholder trends anonymously to assist us in offering better services to our supporters.
3.4 Financial transactions relating to our services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your donations and dealing with complaints and queries relating to such transactions and protecting us from fraudulent transactions.
3.6 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant and lawful request in writing). We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 We have offices and technical computing facilities in the United Kingdom.
4.2 We contract with third parties outside of the European Economic Area (EEA) such as trusted service providers who are authorised to act on our behalf and partner organisations who work on our behalf, or whom we work with in partnership to deliver our projects. Your personal data, such as your name and donation details, may be shared with our regional partners to engrave on a permanent plaque, for instance, if you donate towards a mosque construction project or a food pantry. Our partners or needed charities are in different counties and this list may change depending on our project location and needs.
4.3 We perform international data transfers in compliance with the GDPR’s rules for those transfers, including technical and organisational safeguards for the protection of personal data.
4.4 For the USA and Canada, we rely on the European Commission’s recognition that those countries outside the EU offer an adequate level of data protection (an adequacy decision).
4.5 For the other countries not covered by the European Commission’s adequacy decision, we employ additional safeguards to protect international data transfers, including the use of standard contractual clauses, for data transfers to data controllers or processors, adopted or approved by the European Commission.
4.6 You may request more information about the safeguards that we have in place for the transfer of personal data by contacting us at our support team at Rumi Foundation Ireland, Townhouse, St Mary Square, Athlone, Ireland or emailing [email protected]
5. Retaining, updating and deleting your personal data
5.1 We keep personal data that we process for any purpose or purposes for the least amount of time that is necessary. For example, we will keep a record of donations subject to Gift Aid for at least seven years to comply with HMRC rules.
5.2 In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the maximum period of retention based on our legitimate needs to retain data.
5.3 Additionally, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.4 Where possible, we try to keep your records up to date using publicly available sources. For example, we use the Irish Post Office’s Eircode of Address database. Also, we process changes to your details when you provide them to us.
5.5 We delete your personal data at the end of the retention period, or earlier if we can. For example, if you request data be deleted and removal from marketing, we will do so before our stated retention period; but if you request Gift Aid data to be removed before the end of our legal obligation to Irish revenue, then we will not be able to do so.
6. Your rights
6.1 Your principal rights under the GDPR are the:
a. right to access;
b. right to rectification;
c. right to erasure;
d. right to restrict processing;
e. right to object to processing;
f. right to data portability; and
g. right to complain to a supervisory authority.
6.2 You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.3 You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
6.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the lawful basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.8 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.9 To the extent that the legal basis for our processing of your personal data is:
• consent; or
• that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; and
such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.12 We may withhold personal information that you request to the extent permitted by law.
6.13 We may withhold personal information that you request if the requests are deemed vexatious, manifestly unfounded, excessive or repetitive.
6.14 You may instruct us at any time not to process your personal information for marketing purposes.
6.15 You may exercise any of your rights in relation to your personal data by written notice to us by contacting our support team at Rumi Foundation Ireland, St. Mary’s Square Athlone, Co. Westmeeath, Ireland, or emailing [email protected], or calling 08 996622 18. You can also now register your details to receive updates about our projects and fundraising activities by sharing your details online at https://www.rumifoundqtions.org/
7.1 What is a cookie:
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie.
Cookies are useful because they allow a website to recognise a user’s device, preferences and generally help to improve your online experience.
Cookies may either be “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Please be aware that some areas of our website may not function if your web browser does not accept certain cookies.
You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.
Cookie Name Lifespan Owner and Purpose
PHPSESSID Session This cookie is set by the www.rumifoundations.org service to identify trusted web traffic. It does not correspond to any user ID in the web application, nor does the cookie store any personally identifiable information.
Performance and Statistics
_ga 2 years These are Google Analytics cookies which allow us to anonymously collect statistics about how our site is used. For example, they allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
_gat 1 day
_gid 1 day
PREF 8 months These cookies are set via embedded YouTube videos that appear on our site. They register anonymous statistical data for example how many times the video is displayed and what user settings and preferences are used for playing videos.
No personal data is collected unless you log in to your Google account, in that case, your choices are
linked with your account, for example, if you click “like” on a video.
VISITOR_INFO1_LIVE 179 days
Marketing and Advertising
_fbp 3 months These cookies are used by Facebook and allow us to integrate with Facebook for social sharing and advertising.
ads/ga-audiences Session This cookie is used by Google AdWords and allows us to re-engage visitors for advertising and marketing to raise further funds.
fr 3 months Facebook advertising cookie used for user tracking and ad targeting purposes.
GPS 1 day This cookie is used by YouTube for GPS tracking purposes when watching YouTube videos on our site.
IDE 1 year This cookie is used by Google DoubleClick to register and report the user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.
7.3 Managing your cookies:
By using our website, you agree that we can place the strictly necessary cookies on your device. If you want to restrict or block any of the third-party cookies that we do not control, you should do this through the web browser settings for each browser you use and on each device you use to access the internet.
Here are links to managing your cookies for common browsers:
a. Chrome: https://support.google.com/chrome/answer/95647?hl=en
b. Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
c. Opera: http://www.opera.com/help/tutorials/security/cookies/
d. Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage- cookies
e. Safari: https://support.apple.com/kb/PH21411
f. Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
7.4 If you block all or some cookies, you will not be able to use all the features on our website, some functions may not operate as intended, and may not be able to make donations.
8. Changes to this policy
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 We may notify you of changes to this policy by email or through the private messaging system on our website, apps or services.