Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) –
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Your Consent to Use Personal Data
We use your Personal Data only with your consent. You may withhold or withdraw your consent for IAN to process your Personal Data. Certain Personal Data is required for Us to provide services or merchandise orders to You or to meet our legal obligations, and your withholding or withdrawal of consent to use this Personal Data may prevent IAN from providing the services that You have registered for. Other Personal Data is not required for Us to provide those services to You but is used by Us to provide You with better levels of service or for marketing and communications as well as other purposes. We will advise You which Personal Data You must provide and which is optional. By using IAN’s website and platform, you consent to the collection of certain information. See ‘How Do We Collect Information?’ below.
What Information Do We Collect?
The Personal Data and other information that we process varies depending on your relationship with IAN. Among the Personal Data and other information that We may collect is the following:
• Residential address
• Date of birth
• National identification number
• Telephone number
• IP and MAC addresses and browser information
• Email address
• Banking details, credit or debit card information, or other information needed to process payments
• to or from You
• Demographic information such as your profession, hobbies, education, gender, ethnicity, and
• income. This type of information is never mandatory.
• Other identifying information
Cookies are small text files that are sent to your computer so that our websites can remember the settings and information that you submit. That way You don’t have to re-enter them when You re-visit a page or visit a new page on the same website. A cookie is thus a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
How Do We Collect Information?
We collect Personal Data and other information from You in a variety of ways, including:
• the submission of Personal Data by You to IAN through our websites ;
• the submission of an online order for IAN services or merchandise orders;
• the submission of a project and donation request;
• when We and You communicate by email, telephone, chat line, or otherwise; and
• provision of your Personal Data to IAN by IAN’s business partners.
Data we gather
Information you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Publicly available information
We might gather information about you that is publicly available.
IAN will not contact You by telephone or email to request information such as credit card numbers, account numbers, passwords and pin codes. Do not open or respond to e-mails requesting this type of information. Please contact IAN if You receive such a request.
How Long Do We Keep Your Personal Data?
IAN keeps your Personal Data as long as it is required for the purposes for which it was initially collected. In certain situations, we may need to keep your Personal Data for a minimum period to comply with legal requirements. We do not keep your Personal Data longer than permitted by law.
Where and How Do We Store Your Personal Data?
Your Personal Data is stored by IAN on secure computer servers located in The Netherlands. See Transfer of Personal Data to Third Parties below. All Personal Data is stored according to industry standards. See Security below.
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
How we use your Personal Data
IAN processes Personal Data for a variety of purposes, including:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- to verify, process, and administer your registrations for IAN services
- to ensure a secure ordering of merchandise product process
- to maintain our commercial relationship with You
- to analyse, understand, and respond to your service needs
- to improve the products and services that We offer to You and to develop new products and services
- to meet our legal and regulatory obligations and to protect IAN’s legal and financial interests (including fraud detection and prevention)
- for the provision of services to our Members and Project Managers and compliance with our contractual obligations to them
- to facilitate financial, accounting and administrative functions
- to send commercial and marketing communications to You about services and products from IAN and IAN business partners that We believe may be of interest to you.
- enhance your customer experience;
- fulfil an obligation under law or contract;
- to send you personalized offers* (from us and/or our carefully selected partners);
- to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning client satisfaction.
We may provide your Personal Data to governmental authorities in response to specific requests from those authorities or as part of statistical and analytical reports. When information is provided in statistical or analytical form, information that might specifically identify you will not be disclosed. We use your Personal Data on legitimate grounds and/or with your Consent. On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purpose
On the ground of legitimate interest, we Process your Personal Data for the following purposes
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers (from us and/or our carefully selected partners);
- for other purposes we have asked your consent for.
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 7 years.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:
- Our processing partner
- Our business partners
- Connected third parties
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
Transfer of Personal Data to Third Parties
Security IAN has implemented technological and organizational measures to safeguard your Personal Data from unauthorized or improper access during collection and while it is in our possession. Sensitive information (such as gender, ethnicity, and financial information) is subject to heightened security measures. You should also take measures to safeguard your Personal Data by maintaining the confidentiality of your username and password, logging out of IAN’s websites, closing your web browsers when You have concluded your online activities, and not providing your Personal Data to persons that are unfamiliar to You.
IAN and You may communicate by email or chat and these communications may at times contain Personal Information. While it is illegal to intercept or disclose the contents of email and chat communications, these communications are not secure. We recommend that you do not send sensitive information, such as financial information, by email or chat, and we will not ask you to provide this information in this manner.
Your Right to Access Your Personal Data
You have the right to access your Personal Data, to correct your Personal Data if the information that We have is erroneous, and in some cases to delete your Personal Data. You may obtain a copy or correct or request deletion of your Personal Data by contacting our Privacy Officer at firstname.lastname@example.org or by writing to:
Privacy Officer, Invest in Africa Now! | Sinte Apoloniastraat 150 | 9300 Aalst – Belgium
We may impose reasonable restrictions on requests for access to or to correct your Personal Data and We may charge You a reasonable fee as permitted by law for provision of your Personal Data. If you request deletion of your data, we may not be able to provide services to You. We are permitted to keep certain of your Personal Data in order to meet our legal, financial, audit, and business needs, even if you request its deletion.
Limitation of Liability
Version 1.0 Issue Date: 8th January 2018