GuideStar India Privacy Policy
Last Updated: November 2018
This privacy policy (the “Privacy Policy”) is intended to
inform you of the policies and procedures of GuideStar
India, an initiative of Civil Society Information Services India ("GuideStar
India ,” “we,” or “us”) and its affiliates, with respect to information we
collect. We take the privacy and protection of your Personal Information (as
defined below) very seriously. We may collect Personal Information
from you in accordance with the terms of this Privacy Policy when you visit
GuidestarIndia.org (the "Website").
We are committed to protecting the privacy of visitors to our
Website.
This Privacy Policy is intended to inform the general public and users
about the types of data we collect and how we collect it, as well as how we
use, process, and disclose your information, including personal information, in
conjunction with your access to and use of the Website. Generally, if we process data (defined
below), we will ensure that there is a statutory basis for such processing, or
we will obtain consent. Processing of
Personal Information shall comply with all data protection regulations
applicable to GuideStar India.
For purposes of any regulations Civil Society Information Services India
is a Controller (as defined below). As discussed herein, you can contact us at
any time to: request access to information that we have about you; correct any
information we have about you; and/or delete information that we have about
you. If you have additional questions
about our data collection or storage, please contact us at info@guidestarindia.org.
Definitions
“Account” means a GuideStar India account.
“Anonymous Information” means information not associated
with or linked to your Personal Information; Anonymous Information does not
permit the identification of individuals.
“Controller” means the natural or legal person, public authority, agency or other
body which, alone or jointly with others, determines the purposes and means of
the processing of personal data; where the purposes and means of such
processing are governed by Indian law or if applicable European Law, the
controller or the specific criteria for its nomination may be provided for by Indian
law or if applicable the European Union.
“Personal Information” means any information relating to an identified or
identifiable natural person; an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier
such as a name, an identification number, location data, an online identifier
or to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural person.
“Process” or
“Processing” means any operation or set of operations which is performed on
Personal Information or on sets of Personal Information, whether or not by
automated means, such as collection, recording, organisation, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.
“Services” means the services we offer through the Website,
which, in the case of not-for-profit organisations registered with GuideStar
India, chiefly comprise public information intended to enhance their
transparency, public accountability, visibility and access to resources.
General
security
GuideStar India takes commercially reasonable physical,
electronic, and managerial precautions to prevent the loss and misuse of
Personal Information under our control. Web-based data
transmissions may in principle have security gaps, so absolute protection may
not be guaranteed.
Personal Information we collect
- Information you give that is necessary for the
Services (required; provided as necessity)
Head of organisation / Charity Administrator -
this is the person who is the primary contact for the organisation, and the
person who can update the charity record via a given password. We collect the
name, email address, title, and location of the person acting in this role.
This person’s name and title are publicly displayed. Email address is only
displayed at the individual’s option.
We also collect the phone number of the
organisation (which in some cases may be an individual’s if the Head of
organisation / Charity Administrator so chooses), and the address of the
organisation (which in some cases may be an individual’s if the Head of
organisation / Charity Administrator so chooses.)
If you wish to use the Website, we require the
aforementioned information; if you do not want to provide this information, you
should not use the Website.
- Information you to choose to give
(optional; provided with consent)
●
When you enter any information,
including Personal Information, into any posting or comments within the
Services, we will collect such information and may display it;
o
If you add the names of Board
Members or names and contact details of other officers within the organisation,
you must ensure that you have the consent of these individuals before entering
this information which is clearly marked as optional.
●
When you respond to one of our
surveys, we will collect any information contained in such survey responses;
and
●
When you leave us feedback or
request support, we will collect any information that is contained in your
feedback or support request (including your email address).
If GuideStar India receives Personal Information, it will
only use this information for the purposes described in this Privacy Policy or
in the Terms of Use, and will delete or redact the data upon written or emailed receipt of a request to remove it as per
the conditions detailed below, under the section titled “Your choices regarding your Personal Information”.
Information we collect via technology
When you access any part of our Website, our web server
software automatically logs information provided by your network connection and
web browser software, including the Internet Protocol (IP) address of your
network connection and the type of web browser and operating system that you
are using. Our web server may also log the URL of the file that you are
requesting, the current date and time, and the URL of the last web page
requested by your web browser.
We may utilize cookies on our Website to store your login
information (if any) and your personal preferences for the Services. We may use
both session cookies (which expire once you close your browser) and persistent
cookies (which stay on your computer until you delete them).
We may utilize Google Analytics, a web analytics service
provided by Google, Inc. (“Google”). Google Analytics uses cookies to gather
information relating to the usage of our Website. The information generated by
cookies (including IP addresses) is transmitted to and stored on Google
servers. This information may then be analyzed and compiled into reports on
website activity. Google may also transfer this information to third parties
where required to do so by law, or where said third parties process the information
on Google’s behalf. Google’s policy is to not associate any data gathered from
our Website with any other data held by Google.
You have the option of disabling or not accepting cookies
by changing the preferences in your web browser and thus
permanently deny the setting of cookies. If
you deactivate the setting of cookies in your browser, it is possible that not
all functions of our Website may be entirely used. For example, if you
opt to disable cookies, you will still be able to access our Website, but you
may not be able to use certain features of the Website.
Use of information we collect
In general, we use Personal Information you submit to us
to provide the Services, to you, respond to requests you make, improve the
Services, and offer you additional information, opportunities, and
functionality. We may also use your Personal Information to provide you with
updates about the Services. Finally, we may rely on Personal Information in
order to comply with our legal obligations. Personal
Information is not used for any additional purposes, such as to profile those
who access our Website. None of the Personal
Information we collect, other than that which is displayed on the website
publicly, consistent with this Privacy Policy and the Terms of Use, will be
shared with third parties without your express authorization.
- Providing and improving the
Services
●
Enable you to access and use the
Website and the Services.
●
Operate, protect, improve, and
optimize the Services and experience, such as by performing analytics and
conducting research.
●
Provide customer service.
●
Send you service or support
messages, updates, security alerts, and account notifications.
●
Send you promotional messages and other
information that may be of interest to you based on your preferences (including
information about GuideStar India or related programs).
If you provide feedback to us, we may use and disclose
such feedback for any purpose, provided we will not associate such feedback
with your Personal Information. We will collect any information contained in
such communication and will treat any Personal Information included in such
communication in accordance with this Privacy Policy. We may create Anonymous
Information records from Personal Information by excluding information that makes
the Personal Information personally identifiable to you. We may use this
Anonymous Information to learn more about how visitors use our Website, to
analyze trends, to administer the site, to track visitor movement, and to
gather general demographic information for reporting purposes.
We process this information given our legitimate interest in improving
the Services and our users’ and members’ experience, and where it is necessary
for the performance of the contract with you and/or a legal obligation. You can
opt-out of receiving communications from us by following the unsubscribe
instructions included in our marketing communications or changing your
notification settings within your Account (see also “Your rights” below).
In the case of not-for-profit organisations registered
with us, information is provided by the organisation and supplemented by
GuideStar India and reliable external sources, chiefly for public display of
information so as to enhance the organisation’s transparency, public
accountability, visibility and access to resources. If the organisation chooses
to remove mandatory information, its record will be removed from public display
and will cease to receive the service.
- Complying
with our legal obligations
●
Detect and prevent fraud, spam,
abuse, security incidents, and other harmful activity.
●
Conduct security investigations and
risk assessments.
●
Verify or authenticate information
provided by you (such as to verify your authorization to act as an agent on
behalf of a nonprofit organisation).
●
Conduct checks against databases and
other information sources, to the extent permitted by applicable laws.
●
Resolve any disputes with any of our
users or customers and enforce our agreements with third parties.
●
Enforce our Terms of Use and other policies.
We process this information given our legitimate interest and legal
obligation to protect the Website, to measure the adequate performance of our
contract with you, and to comply with applicable laws. GuideStar India may
process your information if it is necessary for legitimate interests, except
where such interests are overridden by the interests or fundamental rights and
freedoms of the data subject which require protection of personal data.
Your choices regarding your Personal Information
GuideStar India occasionally sends newsletters and
promotional communications to (a) let you know about new features or changes to
our Services, (b) offer you opportunities to participate in special promotions,
events, and surveys, and (c) notify you about services offered by outside
partner organisations. These emails will originate from GuideStar India or its
affiliates. You may choose to opt-out from receiving such communications by following
the unsubscribe instructions provided in the communication. In case of
inability to implement your request due to technical reasons, you have the
option to cancel your organisation’s GuideStar India membership or remove
yourself as a contact for your organisation’s GuideStar India membership. You
understand that any such termination of your Account information may involve
deletion of your Personal Information from our live databases. We will not have
any liability whatsoever to you for any termination of your Account or related
deletion of your information.
You may also occasionally receive administrative site and
service announcement updates via email (such as, but not limited to, notice
that we have changed the Services or the Privacy Policy) when we believe
necessary. You may not opt-out from these announcements (which are not
promotional in nature), as they contain important information about changes to
our Services. If you do not wish to receive these announcements, you have the
option to cancel your organisation’s GuideStar India membership or remove
yourself as a contact for your organisation’s GuideStar India membership. You
understand that any such termination of your Account information may involve
deletion of your Personal Information from our live databases. We will not have
any liability whatsoever to you for any termination of your Account or related
deletion of your information.
Note that in some cases, you may request that we delete
your Personal Information, but we may be required (by law or otherwise) to keep
this information and not delete it (or to keep this information for a certain
time, in which case we will comply with your request only after we have
fulfilled such requirements). When we delete information that we have collected
from or about you, it will be deleted from our active databases but may remain
in our archives. Also, where publicly displayed information was consumed by
visitors to the site, including recipients of data in other formats or
communication, prior to its removal from the site, we would not be in a
position to ensure that the information is removed from the private servers of
such users.
How to change your information
If you would like to change any of your Personal
Information in your GuideStar India Account as a registered not-for-profit, you
can use the " Login and Update My Profile " link from your GuideStar India homepage or you can
send a request to change, correct, or remove information
to info@guidestarindia.org.
If you believe that any of the information contained in an
organisation record on GuideStar India is incorrect and you cannot amend it
yourself through the “Login and Update My Profile ” link, you should contact GuideStar India via email
at info@guidestarindia.org (see also “Your rights” below).
Disclosing information to third parties
1.
Service providers
Since GuideStar India is part of a global network, ,GuideStar India may
rely on the support of a variety of third parties to help us provide the
Service. Service providers may be located inside or outside of the European
Economic Area (“EEA”). The EEA
unites the EU Member States and the three EEA EFTA States (Iceland,
Liechtenstein, and Norway) into a market governed by the same basic rules (such
as GDPR).
For example, service providers may help us: (a) verify your identity or
authenticate your identification documents, (b) check information against
public databases, (c) conduct background or police checks, fraud prevention,
and risk assessment, (d) perform product development, maintenance and
debugging, (e) allow the provision of the Services through third party
platforms and software tools (e.g., through the integration with our APIs), or
(f) provide customer service, advertising, or payment services. These providers
have limited access to your information to perform these tasks on our behalf,
and are contractually bound to protect and to use it only for the purposes for
which it was disclosed and consistent with this Privacy Policy.
If GuideStar India needs to share your information, including Personal
Information, with a service provider, in order to ensure the adequate
performance of our contract with you, we are permitted to do so.
2.
Business transfers
If GuideStar India undertakes or
is involved in any merger, acquisition, reorganisation, sale of assets,
bankruptcy, or insolvency event, then we may sell, transfer or share some or
all of our assets, including your information in connection with such
transaction or in contemplation of such transaction (e.g., due diligence). In
this event, GuideStar India will notify you before your personal information is
transferred and becomes subject to a different privacy policy.
3.
Compliance with law, responding to
legal requests, preventing harm and protection of our rights
GuideStar India may disclose your
information, including personal information, to courts, law enforcement or
governmental authorities, or authorized third parties, if and to the extent we
are required or permitted to do so by law or if such disclosure is reasonably
necessary: (a) comply with our legal obligations, (b) to comply with legal
process and to respond to claims asserted against GuideStar India , (c) to
respond to verified requests relating to a criminal investigation or alleged or
suspected illegal activity or any other activity that may expose us, you, or
any other of our users to legal liability, (d) to enforce and administer our
Terms of Use or other agreements with our users and customers, or (e) to
protect the rights, property or personal safety of GuideStar India , its
employees, its users, customers or members of the public.
4.
Aggregated data
We may also share aggregated
information (information about our users that we combine together so that it no
longer identifies or references an individual user) and other anonymized
information for regulatory compliance, industry and market analysis, insights
about the sector, demographic profiling, marketing and advertising, and other philanthropic
and charitable purposes. We may share this aggregated data with the public.
Links to
outside websites
This Privacy Policy applies solely to information
collected through the Website. Our Website may contain links to outside
websites for your convenience, and such links do not signify our endorsement of
such websites or their contents. GuideStar India has no control over, does not
review and is not responsible for the privacy practices of or content displayed
on other websites. We encourage our visitors to be aware when they leave our
Website and to read the privacy policies of each and every third party website
that collects information from you.
Regarding minors
The Website is not designed for minors under the age of
13. We do not intentionally gather Personal Information about visitors who are
under the age of 13.
Your rights
You may exercise any of the rights described in this section by sending
an email to info@guidestarindia.org.
Please note that we may ask you to verify your identity before taking further
action on your request.
- Managing your information.
You may access and update some of your information through your Account
settings. You are responsible for keeping your personal information up-to-date.
- Rectification of inaccurate
or incomplete information.
You have the right to ask us to correct inaccurate or incomplete
personal information concerning you (and which you cannot update yourself
within your Account).
- Data access and portability.
In some jurisdictions, applicable law may entitle you to request copies
of your Personal Information held by us. You may also be entitled to request
copies of Personal Information that you have provided to us in a structured,
commonly used, and machine-readable format and/or request us to transmit this
information to another service provider (where technically feasible).
- Data retention and erasure
We generally retain your Personal Information for as long as is
necessary for the performance of the contract between you and us and to comply
with our legal obligations. If you no longer want us to use your Personal
Information to provide the Services to you, you can request that we erase your
personal information and close your Account. Please note that if you request
the erasure of your personal information:
● We may retain some of your Personal Information as necessary for our
legitimate programmatic interests, such as fraud detection and prevention and
enhancing safety. For example, if we suspend an Account for fraud or safety
reasons, we may retain certain information from that Account to prevent that
user or customer from opening a new Account in the future.
● We may retain and use your Personal Information to the extent necessary
to comply with our legal obligations. For example, GuideStar India may keep
some of your information for tax, legal reporting and auditing obligations.
● Information you have shared with us may continue to be publicly visible
on the Website, even after your Account is cancelled. However, attribution of
such information to you will be removed. Additionally, some copies of your
information (e.g., log records) may remain in our database, but are
disassociated from personal identifiers.
●
Because we maintain the Website to protect from
accidental or malicious loss and destruction, residual copies of your Personal
Information may not be removed from our backup systems for a limited period of
time.
- Withdrawing consent and restriction of processing
Where you have expressly provided your consent to the processing of your
Personal Information by GuideStar India, you may withdraw your consent at any
time by changing your Account settings or by sending a communication to GuideStar
India specifying which consent you are withdrawing. Please note that the
withdrawal of your consent does not affect the lawfulness of any processing
activities based on such consent before its withdrawal. Additionally, in some
jurisdictions, applicable law may give you the right to limit the ways in which
we use your Personal Information, in particular where (a) you contest the
accuracy of your Personal Information; (b) the processing is unlawful and you
oppose the erasure of your Personal Information; (c) we no longer need your
Personal Information for the purposes of the processing, but you require the
information for the establishment, exercise or defense of legal claims; or (d)
you have objected to the processing (see below) and pending the verification
whether the legitimate grounds of GuideStar India override your own.
- Objection to processing
In some jurisdictions, applicable law may permit you to legally object
to GuideStar India’s processing. In these instances, you may require GuideStar
India not to process your Personal Information for specific purposes (including
profiling) where such processing is based on a legitimate interest. If you
object to such processing, GuideStar India
will no longer process your Personal Information for these purposes
unless we can demonstrate a legal basis for doing so or such processing is
required for the establishment, exercise or defense of legal claims.
At any time, regardless of applicable law, you may object to GuideStar
India processing your Personal Information for direct mailing and outreach purposes. You may, at
any time, ask GuideStar India to cease processing your data for these mailing
and outreach purposes by sending an email to info@guidestarindia.org.
7. Lodging Complaints.
Nothing in this Privacy Policy is intended to limit your right to file a
complaint in the appropriate jurisdiction.
Operating
globally
To facilitate our global operations, GuideStar India may transfer,
store, and process your information within our family of public benefit
organisations in countries both in/out of the EU. Laws in these countries may
differ from the laws applicable to your Country of Residence. For example,
information collected within the EEA may be transferred, stored, and processed
outside of the EEA for the purposes and bases described in this Privacy Policy.
Where we transfer, store, and process your personal information outside of the
EEA we have ensured that appropriate safeguards are in place to ensure an
adequate level of data protection.
Contact us
GuideStar India
c/o Civil Society Information Services
India
108, D-Definity
Jay Prakash Nagar Road 1
Goregaon (E)
Mumbai - 400063.
India.
Email: info@guidestarindia.org
Privacy Policy updates
This Privacy Policy is subject to periodic occasional
revision. If we make material changes to this Privacy Policy, we will notify
you through this Website or, if you have provided your email address, by email.
You agree that such amended Privacy Policy will be effective thirty (30) days
after being posted or sent to you, and your continued access to the Website or
use of the Services after such time shall constitute your acceptance of the
amended Privacy Policy.