Privacy Policy

 

VOW – To End Child Marriage, Inc. (“VOW”, “we”, “us”, “our”) is committed to protecting your privacy. At all times we aim to respect any personal information you share with us, or that we receive from other organizations, and keep it safe. This Privacy Policy (“Policy”) explains how and why we use your personal information and your related rights and options.

This Policy should be read alongside our Terms of Use, which are available here: http://vowtoendchildmarriage.org/terms-conditions.

This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.

The provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services or your interaction with us may be impaired. For example, you may be unable to donate to support VOW.

  1. Who are we?
  2. How do we collect personal information from you?
  3. What personal information do we use?
  4. How and why do we use your personal information?
  5. Will we share your personal information?
  6. Communications for marketing / fundraising
  7. Donor privacy
  8. Third-party websites
  9. The lawful bases for processing personal information
  10. Your rights with respect to personal information
  11. How long do we keep your personal information?
  12. Security / storage of and access to your personal information
  13. Location of servers and transfers of your personal information
  14. Your choices regarding our use of your personal information
  15. Children
  16. Changes to this Policy
  17. Contact us

 

  1. Who are we?

VOW is a non-profit, nonstock corporation incorporated in Delaware, USA. It is a fiscally-sponsored project of the Give Lively Foundation, Inc. (a section 501(c)(3) organisation in the USA, “Give Lively Foundation”). VOW is an independent organization which aims to raise awareness of, and bring an end to, child marriage.

While we are headquartered in the USA, and our website (http://vowtoendchildmarriage.org, “VOW Website”) is operated from there, we aim to raise awareness and develop initiatives on a global scale.

We may therefore collect and use personal information of individuals in other jurisdictions. Please note that there are certain aspects of this Policy which only apply when we are required to comply with some jurisdiction-specific laws, for example the EU General Data Protection Regulation (“GDPR”).

Where the GDPR applies, VOW is a controller of individuals’ personal information.

  1. How do we collect personal information from you?

We collect personal information about you in the following ways:

  • When you give it to us directly

For example, personal information that you submit through the VOW Website by donating to support VOW; or personal information that you give to us when you communicate with us by email or our contact form.

  • When we obtain it indirectly

Your personal information may be shared with us by third parties including, for example, Give Lively Foundation (which accepts donations on our behalf), our partner organizations (such as Crate & Barrel, Malia Mills and The Knot; “VOW Partners”); and sub-contractors in technical services.

  • When it is available publicly

Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services (for example, when you choose to interact with us through platforms such as Instagram, Facebook or Twitter, all of which we use).

  • When you visit the VOW Website

When you visit the VOW Website, we automatically collect the following types of personal information:

  • Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
  • Information about your visit to the VOW Website, including the uniform resource locator (URL) clickstream to, through and from the VOW Website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

We also collect and use your personal information by using cookies on the VOW Website – please see our Cookie Policy.

In general, we may combine your personal information from these different sources for the purposes set out in this Policy.

  1. What personal information do we use?

We may collect, store or otherwise use the following kinds of information (which may be considered personal information according to the laws of the country you are located in when you interact with us):

  • your name and contact details (including postal address, telephone number and email address);
  • details about your wedding; such as its date and location;
  • your organization and details about your role there;
  • details of your interest in VOW and our aims / ideals;
  • your financial information, such as bank details and / or credit / debit card details, account holder name, sort code and account number (so that we can process your donation or purchase of a VOW product);
  • information about your computer / mobile device and your visits to and use of this website, including, for example, your IP address and geographical location;
  • your social media identity;
  • information about our activities / products which you use / in which you have expressed an interest / which we consider may be of interest to you; and / or
  • any other personal information which we obtained as per section 2 of this Policy.
  1. How and why do we use your personal information?

Your personal information, however provided to us, will be used for the purposes specified in this Policy. In particular, we may use your personal information for the following purposes:

 

  • to send you information about our work, news, events, activities or opportunities; either where you have expressed an interest or where we think the information may be of interest to you (where required by applicable law, only where you have provided your consent to receive such information);
  • to register your organization as a partner / supporter;
  • to respond to inquiries from you and communicate with you in general;
  • to assist in providing you with the services, products and /or information you have requested;
  • to process your donation;
  • to ensure and improve the quality and / or security of the VOW Website;
  • to improve the content or services offered through the VOW Website;
  • to detect, investigate, and protect against any activities that may violate our policies or the law and to establish, defend against, or enforce any related claims;
  • to analyse and improve our work, activities, or information (including the VOW Website), or for our internal records;
  • to report on the impact and effectiveness of our work; and / or
  • to cooperate or comply with law enforcement or to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and / or law enforcement bodies with whom we may work.
  1. Will we share your personal information?

In general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Policy.

Non-exhaustively, those parties may include:

  • our third party service providers (“Service Providers”) that help us operate and provide services in connection with the VOW Website.
  • other independent contractors, consultants, and third-party agents, affiliates, and partners which we may use to perform services on our behalf (for example third parties who help us organize and administer our events). All individuals and entities in these sections 5.1 and 5.2 will only have access to your personal information as strictly necessary to perform their functions and are contractually obligated to maintain the confidentiality and security of any personal information collected from the Site.
  • The VOW Partners and any other partners / supporters with which we may enter into agreements in the future.
  • The Girls First Fund (a philanthropic fund of Capital for Good USA, a US 501(c)(3) public charity [insert link], “GFF”), with which VOW works to achieve its charitable mission of ending child marriage.

We also reserve the right to disclose and use personal information and other information in special circumstances, including enforcing our Terms of Use  to comply with legal obligations or law enforcement requirements which are binding on us, to address actual or suspected illegal activity, to protect our property or rights, to protect the rights and safety of anyone, to establish, defend or enforce legal claims, or for other reasons we determine in good faith are necessary, appropriate, or reasonable according to the circumstances.  If we ever merge with, are acquired by, or otherwise consolidate with another organization, personal information may be transferred along with our other assets.

  1. Communications for marketing / fundraising

We may use your contact details to provide you with information about our work, events, activities, and/or campaigns which we consider may be of interest to you (for example, about campaigns similar to those in which you have expressed an interest or news about the progress we are making).

In some jurisdictions, such as EU member states, there are restrictions on how we can do this. In general, where we contact you with such material via email, SMS or telephone, we will not do so without your prior consent (unless we are allowed to do so by the applicable data privacy law of the jurisdiction in which you are based).

Where you have provided us with your consent previously but do not wish to be contacted by us about our work, events, services and/or products in the future, please let us know by email at info@vowtoendchildmarriage. Alternately, you can opt out of receiving emails of this nature from VOW at any time by clicking the “unsubscribe” link at the bottom of our emails.

  1. Donor privacy

VOW values and respects the privacy of its donors.  As with all other personal information, we do not share (except as described in this Policy), loan, trade, rent, or sell our donor information to any other organization, nor will we send mailings to our donors on behalf of any other organization.

 

When you use our secure online donation function you will be directed to Give Lively, LLC, a specialist payment service provider, which will receive your financial information to process the transaction. (As described above, during the term of VOW’s fiscal sponsorship, your donation will be made to Give Lively Foundation, a US 501(c)(3) public charity.) We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.

We maintain historical records of donor giving histories for certain types of gifts. This information is gathered so Give Lively Foundation, VOW’s fiscal sponsor, can properly acknowledge gifts for tax purposes and is also used by VOW to analyze giving histories.

This section applies to donations and donor information received online or offline.

 

  1. Third-party websites

The VOW Website contains links to third-party websites, including websites of VOW Partners (“Third-Party Sites”).  Third-Party Sites may collect information about you when you interact with them through those links.  If you follow any link to a Third-Party Site, you should review those sites’ privacy policies to find out how they protect your privacy.  We are not responsible for Third-Party Sites or their privacy practices.

  1. The lawful bases for processing personal information

In order to comply with applicable data protection laws, in particular the GDPR, we are required to rely on one or more lawful bases for the processing of your personal information. In accordance with the purposes for which we collect and use your personal information, as set out above, the lawful basis for processing your personal information will typically be one of the following:

  • Where you have provided your consent for us to use your personal information in a certain way (for example, we may ask for your consent to email you with updates about our work, services and opportunities which we consider may be of interest to you).
  • Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work).
  • Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
  • Where there is a legitimate interest in us doing so. In brief, the GDPR allows us to collect and use your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights). In broad terms, our “legitimate interests” means the running of VOW as a non-profit organisation committed to bringing an end to child marriage across the world. Where we use your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive in the circumstances (unless, for example, we are otherwise required to by law).
  1. Your rights with respect to personal information

Persons located in the EU may have certain rights in relation to their personal information under the GDPR.  Persons in other jurisdictions may also have certain rights in relation to their personal information.  We will honor your requests to exercise the following rights to the extent possible and as required under the applicable law:

 

  • Right to rectification.If you believe our records of your personal information are inaccurate or out of date, you have the right to ask for those records to be corrected / updated. You can also ask us to check the personal information we hold about you to check whether it is accurate / up to date.
  • Right to withdraw consent. Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes, or to unsubscribe from our email list at any time.
  • Right of access.You can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and, where reasonably required, we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions which may apply.
  • Right to object.You have the right to object to processing where we are (i) processing your personal information in reliance on the lawful basis of legitimate interests (see section 9 above), (ii) using your personal information for direct marketing, or (iii) using your personal information for statistical purposes.
  • Right to erasure.You may request that we erase your personal data. We will comply, unless there is a lawful reason for not doing so. In many cases, we shall use limited personal information to suppress further communications with you, rather than delete it entirely, so that we can comply with your preferences.
  • Right to restrict.You have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
  • Right to data portability.To the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a commonly used machine-readable format.
  • Rights related to automated decision-making. You have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal effects on you or similarly significantly affects you, unless such a decision (i) is necessary to enter into / perform a contract between you and us / another organization; (ii) is authorised by EU or an EU member state law to which VOW is subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.
  • Right to lodge a complaint with your local data protection authority.For individuals based in the EU, you also have the right to lodge a complaint with your local data protection authority about how we use your personal information. A list of the data protection authorities in each member state, including their contact details, can be found here: http://ec/europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. For further information, please contact us using the details below.
  1. How long do we keep your personal information?

In general, we will keep your personal information for as long as it is required in connection with the purpose(s) for which was collected and/or processed. In some jurisdictions, there are limits on how long we may retain your personal information. Where these limits apply, in general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records 6 years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see section 10.5 above), we will remove it from our records at the relevant time.

 

If you request to receive no further contact from us, we will keep some basic personal information about you on our suppression list in order to comply with your request and avoid sending you unwanted communications in the future.

 

  1. Security / storage of and access to your personal information

VOW is committed to keeping your personal information safe and secure, and we have appropriate and proportionate policies as well as organizational and technical measures to safeguard your personal information (for example, all donations directed from the VOW Website and made through Give Lively, LLC are encrypted). Of course, no transmission over the Internet can be guaranteed to be 100% secure, so you provide your personal information at your own risk.

 

  1. Location of servers and transfers of your personal information

As an international organization headquartered in the USA, your personal information will be accessed and processed in the USA.  In addition, your personal information may be transferred outside the USA to our Service Providers with locations in other countries.

Certain countries have rules relating to the transfer of personal information across borders and require us to ensure that personal information remains protected according to appropriate standards (for example, EU member states under the GDPR).

 

If you are an individual based in the EU, please note that some countries outside the EU have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals.

 

When necessary, we will take all reasonable steps to ensure that we and other recipients of your personal information implement appropriate safeguards (such as by entering into contractual clauses obliging us / such recipients to take steps to protect your personal information) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Policy. If you have any questions about the transfer of your personal information, please contact us using the details below.

 

  1. Your choices regarding our use of your personal information

If you wish to review, update, correct, or remove the information we have for you, please contact info@vowtoendchildmarriage.org.

 

If you no longer wish to receive communications from us, you can also unsubscribe by clicking on the “unsubscribe” button in any email communication you receive from us.

 

Some browsers have incorporated Do Not Track (“DNT”) preferences.  As there is not yet an industry-standard DNT protocol on how to interpret DNT signals, we do not honor DNT signals from browsers at this time.  However, you may refuse or delete cookies to prevent tracking activities.

 

  1. Children

The Site is directed at an adult (i.e. 18 and over) audience and we do not knowingly collect information from or about children. However, when we do so, where required, we will not do so without their consent or, where required, the consent of a parent/guardian.

 

  1. Changes to this Policy

We may update this Policy from time to time.  If we make significant changes to our Policy, we will notify you.  VOW may update this Policy by posting a new version on this webpage.

 

  1. Contact Us

For any questions you may have about this Privacy Policy or our data practices please contact info@vowtoendchildmarriage.org.

Last updated: April 1st, 2019

 

As of 10/8/2018, VOW uses the following Service Providers to operate the Site:

• Media Temple (web hosting) (Privacy Policy)

• Give Lively (donation acceptance and administration) (Privacy Policy)

• Mail Chimp (email management) (Privacy Policy)

• Google Analytics (website analytics) (data practices)