Sawti’s Privacy Policy
A. Introduction
This Privacy Notice explains the types of personal data we may collect about you when you interact with us.It also explains how we process, store, handle and use that data and how we keep it safe.
We take your data very seriously and will continue to review our activities in this area and update the policy as necessary. We will notify you of any significant changes, or you can visit this page to see our policy at any time.
More information about your rights can be found at www.knowyourprivacyrights.org.
Please get in touch if you have any questions or concerns
B. What does the law say?
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking for your consent on a form we ask you to fill out, when you sign up to the global campaign or to join the team or by asking you to agree to our use of cookies, among other ways.
Sometimes you might give your consent implicitly, such as when you send us a message by email to which you would reasonably expect us to reply.
In specific situations, we can collect and process your data with your consent. For example, if you are not a member, but wish to receive email newsletters.
You may withdraw your consent at any time by instructing us to do so at sawti@impactlebanon.org. If you express a desire to withdraw your consent using any other means, including but not limited to, making requests verbally, on Whatsapp groups or on other social media platforms, or by contacting us through a telephone, we cannot guarantee that the withdrawal of your consent will be adequately processed in our system. Please make sure to withdraw your consent in writing to our email address.
Contractual obligations
When you subscribe to receive communication from us or join the global campaign or join the team, a contract is formed between you and Impact Lebanon.
To perform and comply with our contractual obligations, we must process the information you provide us. For example, if you join the team, we need to gather information about the projects you are involved in, in order for us to support your work. In order to deliver our membership service to you, to enable you to attend any of the events or meetings, to provide you with information we believe to be relevant to you, we will need to contact you to ensure that this obligation can be fulfilled.
In addition, we may aggregate the information you give us in a general way and use it to understand and provide generic information on your membership in the team or global campaign. We will do this as long as you are a member or you are subscribed and will cease to do this once your membership is terminated or when you unsubscribe.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting Impact Lebanon Ltd to law enforcement.
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our organisation and which does not materially impact your rights, freedom or interests.
For example, we will write to you to invite you to an event, volunteer in a project, announce the results of a project or campaign, or provide you with updates.
C. When do we collect your personal data?
We will collect your personal data in a number of ways including, but not limited to:
When you sign up for a newsletter;
When you sign the pledge;
When you attend events hosted by Sawti or by Impact Lebanon;
When you engage with us on social media;
When you visit our website;
When you sign up to the global campaign or to join the team; and
When you contact us by any means with questions, information requests etc. When you contact us, whether by telephone, through our website or by email, we may collect the data you have given to us to reply with the information you need. We keep personally identifiable information associated with your message, such as your name and email address to be able to track our communications with you to provide a high-quality service.
When you’ve given a third party permission to share with us the information they hold about you.
We will ensure that this information is processed in a lawful manner and is only used for relevant and necessary purposes.
D. What sort of personal data do we collect?
If you are one of our members: your name, email address, telephone number, how you choose to help us.
For non-members or for events, we will tell you what information aside from your email address and name we are collecting and why we are collecting it.
E. How and why do we use your personal data?
We want to support the mission of Impact Lebanon and Sawti. If you are a member of the global campaign or the team, we will contact you regularly to ensure that you can effectively contribute.
If you are not a member but choose to sign up to our communications, then we will also contact you. Of course, are free to opt out of hearing from us by any of these channels at any time by communicating to us your intention to unsubscribe or end your membership.
We may use your data to send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
We may also use your data to comply with legal obligations or to carry out fraud checks as necessary to protect our organisation and mission.
To send you surveys and feedback requests to help guide and improve our work.
We may aggregate your information in a general way and use it to provide class or sector information, for example to monitor the performance of a page on our website.
We will only share your data with third parties with permission and if we are working with them to deliver services or events and only if it is absolutely essential in order to allow you to attend that event (for example, attendance to a seminar at a university where it is required of us to provide a list of attendees).
F. We will ensure that your data is kept secure and take all appropriate steps to protect it.
We will put in a place a range of measures and data security protocols to ensure that your data is kept safe and secure, including keeping all data password protected.
If you are a subscriber to our mailing list, when we are sending announcements, newsletters or updates to our mailing list of subscribers, we will anonymise your email by placing it in BCC.
If you are a member of the campaign or team, your email addresses will be visible only to the other members working on the same project and to the board of directors and founders of Impact Lebanon and the Sawti team.
We are only responsible for putting in place measures to protect your data when you contact us directly using our telephone numbers, email address or when we ask you to fill a form. On any medium where your data is available to others upon your subscription to it, such as joining a group on Whatsapp to receive announcements, follow us on Instagram or like us on Facebook, we cannot prevent others from accessing your telephone numbers or social media account handles since this information can be seen publicly. In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at sawti@impactlebanon.org.
G. Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
If you have signed up to receive email communications from Impact Lebanon or Sawti, you will continue to receive these until you actively unsubscribe.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
H. Who do we share your personal data with?
We will sometimes share your personal data with trusted third parties, if we have your permission to do so. We will tell you who these third parties are if we are sharing personal data with them and if it is not to be reasonably expected (for example, when we send seminar invites, we indicate the university or venue in which it will be held and it should be reasonably expected that the list of attendees will be provided to the university or venue). We provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. This may include partners on our programmes. We continue to process your information on this basis until youwithdraw your consent, or it can be reasonably assumed that your consent no longer exists.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our members into consideration.
We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
I. What are your rights over your personal data?
You have the right to request:
Access to the personal data we hold about you
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that Impact Lebanon holds at any time, and also to have that information corrected if it is inaccurate.
To exercise your rights over your personal data, including all of the above, please contact sawti@impactlebanon.org.
If we choose not to action your request, we will explain to you the reasons for our refusal.
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
J. Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
K. Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
L. Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
M. How can you stop the use of your personal data for direct marketing?
To stop direct marketing communications from us, please email sawti@impactlebanon.org.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
N. Complaints on our privacy policy
If you have any complaints about our privacy policy or you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, please raise the issue with us by sending an email to sawti@impactlebanon.org and provide us with a reasonable amount of time to respond. To expedite, you may contact us individually.
If your concern is not handled, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites).
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.