Personal Data Protection Policy

Last Updated: April 17th, 2024

Right To Play is an international charity headquartered in Canada, whose mission is to protect, educate, and empower children to rise above adversity. Right To Play International supports children in development and humanitarian contexts in Africa and the Middle East. Right to Play International has offices in Canada, Germany, Netherlands, Norway, Switzerland, United Kingdom, United States, Mali, Senegal, Ghana, Mozambique, Tanzania, Burundi, Rwanda, Uganda, Ethiopia, Lebanon, Jordan, Palestinian Territories and Pakistan (together with Right to Play International, “(“Right To Play”, “we” “us”, “our”).

The purpose of this policy is to is to inform our program participants, donors, and others who interact with us, including through our website located at https://righttoplay.com/en/ (the “Website”), of how we collect, use, disclose and protect personal data. It also tells you about the rights and choices you have with respect to your personal data, and how you can reach us to get answers for your questions.

Please note, our privacy practices are subject to the applicable laws in the places in which we operate. Please see additional region-specific terms below that apply if you are located in those geographic regions, or as required by applicable laws.

Inquiries. If you contact us with an inquiry, we will ask that you use this portal to provide your name and contact information in order for us to respond to your inquiry.

TABLE OF CONTENTS

  1. Collection and Use of Personal Data
  2. Information Collected Automatically
  3. Disclosure of Personal Data
  4. Third Party Links
  5. Safeguards
  6. Retention of Personal Data
  7. Your Rights
  8. Updates to our Privacy Policy
  9. Contact

1 - COLLECTION AND USE OF PERSONAL DATA

We collect personal data directly from you unless we have your consent or are legally permitted to collect your personal data indirectly.

Donations. If you donate to Right To Play, we will collect your contact information, address, email, and payment information to process your donation. We will collect additional information that you provide to us, including: phone number, date of birth, gender, nationality, languages, and other information which is used to assist our fundraising efforts.

Marketing Communications. We offer the ability for you to sign-up to receive our newsletter and other promotional communications, in which case we collect your name email address, and other information that you provide in order to send you the communications you have requested to receive. You can opt-out of receiving promotional communications from us by following the opt-out or “unsubscribe” instructions provided in our emails, or by contacting us as set out in the “Contact” section below. Please note that upon unsubscribing, you will continue to receive transactional and account-related electronic messages from us.

Job Applications. If you apply for a job at Right To Play you may be asked to provide us with certain personal data about yourself, such as your resume, cover letter, or similar employment-related materials. We use this information for the purposes of processing and responding to your application and assessing your suitability for current and future career opportunities.

We may collect other information that you choose to provide to us, or that we collect with your consent.

Volunteers and Program Participants. If you participate in one of our programs as a volunteer or a participant, we collect your name, age, address, contact information, email, date of birth, emergency contact details, gender, nationality, social media information, and other information you choose to provide in order to implement the program.

Use. We use the personal data we collect for fundraising and program implementation purposes. This includes:

  • Processing payments from donations;
  • Communicating with you about events or fundraising initiatives that may be of interest;
  • Communicating with you about the impact of our programs;
  • Aggregating or otherwise anonymizing your personal data for use for technical, research, and analytical purposes;
  • Better understanding how you use the Website in order to improve the Website;
  • Requesting and collecting feedback and responding to requests and complaints;
  • Meeting our regulatory and other legal reporting obligations;
  • Managing our charity, including to maintain records for reasonable periods, enforce our agreements, and collect amounts owing to us.

Where personal data is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal data by contacting us as described in the “Contact” section below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal data, we may not be able to provide certain parts of our services.

2 - INFORMATION COLLECTED AUTOMATICALLY

Cookies. The Websites use cookies (small files containing program code that reside on your computer), to provide usage statistics about the Website, and to understand where visitors learn about the Website. We also may use cookies to simplify the re-entering of your data. You can adjust your browser settings to opt out of the use of cookies by having your browser disable cookies. Look for the cookie options in your browser in the Options or Preferences menu.

Log Files. When you use the Website, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with the Website, domain names, landing pages, and pages viewed, mobile carrier, and similar information. Log files help us to monitor, analyze, improve and maintain the Website and to diagnose and fix technical issues.

Device Identifiers. When you access the Website using a mobile device, we collect information about your device contained in your mobile device’s “device identifier.” This device identifier includes information such as the type of device you are using, its operating system, and mobile network information. We use this information to optimize the Website and fix technical issues.

Analytics. We may use third party service providers like Google Analytics to collect information about your use of the Website, such as the features used and time spent on the Website, to help us better understand our users and improve the Website. The information we gather is used in an aggregate, non-identifiable form. For information about how information is processed in connection with Google Analytics, please read the Google Analytics Policy here.

Social Media. If you interact with us on social media, we collect information that you disclose to us, or that the social media platforms disclose to use. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.

3 - DISCLOSURE OF PERSONAL DATA

Service Providers. We may transfer personal data to third party service providers that provide certain services on our behalf, such as data hosting and processing, marketing, analytics, information technology services, and payment processing. Some of these service providers may be located outside of your jurisdiction of residence, including in the United States. While outside of your jurisdiction of residence, personal data will be subject to applicable foreign laws, which may permit government and national security agencies to access your information in certain circumstances. For more information about the way in which our service providers treat personal data, please contact us as set out in the “Contact” section below.

Right To Play National Offices. We may transfer personal data to our national offices to coordinate global marketing and fundraising initiatives. Some of our national offices are outside of Canada, including in the United States, Germany, Netherlands, Norway, Switzerland, and the United Kingdom. While outside your jurisdiction of residence, personal data will be subject to applicable foreign laws, which may permit government and national security agencies to access your information in certain circumstances. For more information about the way in which our national offices treat personal data, please contact us as set out in the "Contact" section below.

Other. We may disclose personal data to meet our legal and regulatory obligations or otherwise as permitted or required by law, including to comply with a subpoena or warrant, to law enforcement in connection with an investigation, to protect our rights and the safety and

security of our employees, and to enforce our agreements and collect debts owed to us.

4 - THIRD PARTY LINKS

The Website may contain links to other websites that Right To Play, does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal data. We encourage you to read the privacy policy of every website you visit.

5 - SAFEGUARDS

We protect personal data using safeguards that are appropriate to the sensitivity of the information. These safeguards may include measures to protect against unauthorized access, alteration, disclosure or destruction of personal data. We limit access to personal data to our employees and service providers who require access in connection with their role or function. Each of our employees is responsible for maintaining the confidentiality of all personal data to which they have access. We keep our employees informed about our policies and procedures for protecting personal data. Despite these measures, since no system or security measure is completely secure, it is possible that personal data may be lost, stolen or accessed without authorization.

6 - RETENTION OF PERSONAL DATA

Personal data is maintained on our servers or those of our service providers and is retained as long as necessary for the fulfilment of the purposes for which it was collected, in accordance with applicable law.

7 - YOUR RIGHTS

You may request access to or correction of your personal data in our custody or control. You may also have the right, in specified circumstances, to object to our use of your personal data, to request the deletion of your personal data or restrict its use, to request a copy of the data you have provided to us to use for your own purposes, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. To exercise any of these rights, please contact us in writing using the contact information set out in the “Contact” section below.

8 - UPDATES TO OUR PRIVACY POLICY

If we change our Privacy Policy, we will post those changes on this page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page.

9 - CONTACT

For questions, inquiries or requests, please contact our Vice President Information Technology, Mike Prime at dataprivacy@rightotplay.com, or complete a request form via our privacy rights portal.