Last updated 4 November 2022
HSI is committed to your right to privacy and to keeping your personal information private and secure. This notice tells you what to expect when we collect personal information.
1. Who we are and what this notice is about
Humane Society International, a charitable non-profit organization headquartered at 1255 23rd Street, NW, Suite 450, Washington, DC, USA, is one of the largest animal protection organizations in the world with affiliated organisations in several countries that share a common mission to promote the humane treatment of animals worldwide and to foster respect, understanding and compassion for all creatures through public education, awareness and direct animal care programs. The affiliated organisations include the Humane Society International (UK), Company Number 04610194 and Charity Number 1098925, whose registered office is at Robinsons, 5 Underwood Street, London, N1 7LY, United Kingdom. For purposes of this policy, the terms (“HSI”, ““we”, “our”, “us”) refer collectively to Humane Society International and Humane Society International (UK). Our UK Representative is the Humane Society International (UK), firstname.lastname@example.org.
This privacy notice applies to information collected by us whenever you interact with HSI, including when you visit or browse the URL http://www.hsi.org or any associated subdomain or our social media pages or otherwise interact with us. When you interact with us, you consent to our collection, use and disclosure of information about you as described in this privacy notice.
This privacy notice applies to information collected by us whenever you visit or browse the URL https://www.hsi.org (the “website”) or interact with us.
HSI is the “data controller” of the personal data processed for the purposes of the Data Protection Act 2018 (the DPA) and the UK General Data Protection Regulation (the UK GDPR). Personal data is defined in the DPA and UK GDPR as any information relating to an identified or identifiable natural person.
This notice contains information about:
- Why we collect personal information about you
- What personal information we collect from you and how we collect the information
- How we use your personal information
- How long we keep your personal information
- Information sharing and third parties and where we store your personal information
- How we keep your personal information secure
- Your rights
- How you can complain or contact us
Please read this privacy notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this privacy notice in general or any part of it, you should not access the website or use our services.
We keep this notice under regular review. HSI reserves the right to modify or amend this privacy notice at any time and for any reason. Please check back frequently to see any updates or changes to this policy.
2. Why we collect personal information about you
- We hold and process supporters’ and visitors’ personal data for a variety of reasons:
- To keep a record of donations made and actions taken by our supporters;
- To maintain a record of our contacts and communications with our supporters and members of the public;
- To contact supporters and potential supporters by mail, telephone, text or email, to keep them up to date on the work of HSI and the ways in which they can help us in our efforts and to send them marketing information about our activities, news, action alerts and fundraising where we have their consent or are otherwise allowed to;
- To better meet the needs of our supporters;
- To fulfill contractual obligations entered into with supporters e.g. online donations and purchases;
- To comply with legal obligations;
- To manage our organisation; and
- For planning, analysis and other operational purposes such as understanding HSI supporters and potential donors or to inform our legacy giving program; and
- To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted; and
- To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted.
3. Information we collect about you and how we collect the information
Information you voluntarily provide
HSI collects and maintains certain personal information about you when you interact with us, such as, for example, when you send us an e-mail or complete any of our forms, sign up for mobile text alerts, request information from us, make a donation, subscribe to one of our newsletters, forward a web page, electronic postcard, electronic ballot or electronic newsletter, provide information when contacting or speaking with us or interacting with us via telephone or social or other electronic media, participate in an HSI event, give us feedback or make a complaint, or request information on leaving HSI in your will or let us know you have left HSI in your will, or give us feedback or make a complaint. Depending on how you choose to interact with us, such information may include, among other things, your name, mobile phone number, landline telephone number, mailing address, e-mail address, campaign interests and preferences, donation history, images, photographs or video footage if you take part in an HSI event, or any other information you share with us; it may also include the names and e-mail addresses of those to whom you forward HSI electronic content, and other information you provide to HSI. You may be asked to provide credit card information to contribute to HSI, purchase certain information or materials from HSI, or subscribe to various HSI publications. To collect payment from you, we enable the collection of your payment information (which comprises the credit/debit card’s number, the card holder’s name, expiration date and CVV), however these are provided direct to our authorised payment providers, and are not stored or accessible by us.
hsi.org also collects certain usage information to better understand how visitors use our website, which includes your IP address, geolocation (collection of the physical location of your device), Url you are coming from before visiting the Website, web browser and browsing data, browser type, device type, the fact that you are visiting our website or clicking on our content, length of website visit and number of page views. HSI.org logs these IP addresses, geolocation, url’s, device information such as identifier, name and type of operating system, mobile network information and web information such as browser type and pages accessed on the HSI website, and aggregates them for system administration and to monitor the use of our site. We use the aggregated information to measure the number of visits to our site, the average time spent on our site, the number of pages viewed, and various other site statistics. This monitoring helps us to provide a more useful and engaging online experience to HSI.org visitors, and helps us to improve the quality of our content.
HSI and other third-party vendors, including Google and Facebook, use first-party and third-party cookies together for re-targeting, where you may see an ad for HSI based on past visits to our website displayed on other sites you visit.
Publicly available information
We may use publicly available sources to keep your records up to date and check for changes of address and for deceased and gone away records, and undertake data cleaning activity. This allows us to better direct our resources and efforts, manage supporter relationships and ensure data remains accurate, up to date and compliant. We may obtain this publicly available information directly or from third parties; for example, the Royal Mail’s National Change of Address Database (NCOA LinkTM), The National Deceased Register, Mortascreen, The Bereavement Register, Mortality Suppressions from Experian or other trusted source lists deemed reliable. We may use trusted third-party providers to undertake data cleaning activities on our behalf.
When administering legacy gifts, we may occasionally be required to collect information relating to non-professional (lay) executors who are administering estates in which we have a legacy entitlement. Executors may provide their details to us themselves or, where appropriate, we may access the Probate Registry in order to obtain their details as listed within a deceased’s will. We may also receive this information from third parties who undertake searches of the Probate Registry on our behalf.
We may collect information about you from publicly available sources to help us understand more about you as an individual and your ability to provide financial support for our charitable programs and activities; including, by carrying out wealth screening, a process which uses trusted third-party partners to automate some of this work. We may use information gathered from public sources alongside the information you provide to undertake analysis of who might be willing to financially support HSI and to understand the preferences of our supporters about events, communication and services. By doing this, we can focus conversations we have with you about fundraising in the most effective way, and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you. If you do not wish HSI to undertake this type of processing activity of your personal data, please e-mail us at email@example.com.
If you are a parliamentarian, we may obtain from public sources and keep a record of your contact details, your political opinions, your attendance at events and other information to inform our advocacy campaigning.
Our legal basis for collecting and using the information described above will depend on the specific information concerned and the context in which we collect it. We, however, will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we may have a legal obligation to collect personal information from you.
4. Ways information about you is used
The laws on data protection provide a number of different reasons (legal basis) for organisations to collect and process your personal data. We generally process data on the basis that it is necessary for the pursuit of our legitimate interests. We process data to pursue our legitimate interests in ways which might reasonably be expected and which do not materially impact your rights, freedom or interests. For example, by, among other things, sending direct marketing information to keep our supporters updated on HSI projects, activities, news and action alerts, and identifying supporters and donors who may have an interest in, and financial ability to, support HSI and particular aspects of our work. We will only do this where we have reason to believe that this information will be of interest to you.
In circumstances where required by applicable law, we will rely on consent as a basis for processing personal data and we will specifically obtain your consent in the course of collecting the data. We may also need to collect and process your data if we are required to by law. We may also use data to improve our level of service. Where we do this, we do it to help inform us how to improve the way we work since both we and those we deal with have an interest in us doing so.
We will use the information you voluntarily provided to: contact you regarding animal protection-related issues we feel you may be interested in, to keep you updated regarding HSI’s programs, to extend an invitation to you to support our programs, to sign you up for our news or action alerts, to contact you via email or post, and to enforce our website terms and conditions. We may also send such information to the people whose e-mail addresses you provide when forwarding HSI electronic content. When we do so, our sole intent is to enlarge our family of informed animal advocates and organizational supporters.
Every recipient of our electronic communications can quickly and easily “opt out” of future such communications by following the instructions on any electronic communication we send.
5. How long do we keep your personal data?
We will retain your personal data for as long as is necessary for the relevant activity, for example we will keep a record of donations subject to gift aid for the period of time required to comply with applicable tax rules (for example seven (7) years in the case of HMRC).
While we will retain your personal information for as long as necessary, in relation to personal data obtained for direct marketing we will supress your data and not market to you if you have not contacted us or donated to us for a period of sixty (60) months.
6. How do we share your personal data?
We do not sell, rent or lease your personal information to third parties for marketing purposes.
We may directly upload voluntarily provided information into third-party platforms that have provided us with assurances that they process personal information under suitable data protection arrangements and security controls, such as Facebook and Google, in order to serve content-specific advertisements. We participate in Facebook’s “Custom Audiences” and “Lookalike Audiences” which enables us to display advertisements to our existing or potential supporters via Facebook or to suppress certain HSI advertisements from our existing supporters’ Facebook feeds (e.g. an advertisement directed at signing a petition when you have already signed it). In order to do this, we provide supporter name, email address, city, zippostal code and telephone number to Facebook to enable them to determine if you are a registered account holder with Facebook. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account. Before the data is uploaded by Facebook for the matching process, the information is hashed and will be unidentifiable at an individual level. Hashing is a type of cryptographic security method that turns your identifiers into randomized code and cannot be reversed. Depending on your settings our advertisements may then appear when you access Facebook and on your Facebook feed, as well as on other third-party websites and applications. For more information please read the Facebook Business page about Custom Audiences and Facebook’s Data Policy.
We may disclose your information to third-parties for carrying out the purposes as described in this privacy notice. These categories of third-party recipients include:
- given that we are part of an international organisation, your personal information may be transferred to and stored by affiliated organisations outside of the UK. For example, when we collect your personal information, it will be transferred to, processed by and stored with our US affiliate – Humane Society International, a charitable Washington, DC nonprofit corporation registered at 1255 23rd Street, NW, Suite 450, Washington, DC, USA. We take the privacy of our supporters and visitors seriously and therefore take steps to safeguard your information, including ensuring an adequate level of data protection in accordance with UK standards in effect as of the date of this privacy notice. These steps include use of Standard Contractual Clauses for transfers of personal information between our UK and US affiliates, which require the US affiliate to protect UK Residents’ personal information in accordance with applicable data protection laws.
- advertisers and advertising networks, including Facebook and Google, that require the data to select and serve relevant adverts to you and others. We use cloud-based providers who operate within the UK under suitable data protection arrangements and security controls in place in accordance with the requirements in UK GDPR and the DPA;
- third-party service providers who have provided us with assurances that they process personal information under suitable data protection arrangements and security controls in place in accordance with the requirements in UK GDPR and the DPA. These third-party service providers include, among others:
-cloud storage providers, including Saturn located in the United States, which store your data in the United States to store the personal data you provide and for disaster recovery services;
−to our authorised card payment providers, including Sagepay, Paypal UK, Paysafe, Committed Giving/Telebank and Engaging Networks, to collect payment from you;
-IT Services providers, including Telebank located in the United Kingdom, ROI Solutions Company located in the United States which store your data in the United States and Engaging Networks, located in the United States which store your data in Canada, who we use to store our customer relationship management information, etc.;
-fundraising consultancies and research services providers;
-analytics services providers, including Tableau and Google, both located in the United States, that assist us in the improvement and optimisation of the Website;
-data cleaning providers; and
-free will service provider, including Ashton Maund Associates Limited (trading as Capacity Marketing for Charities) / National Free Wills Network.third-party service providers who have provided us with assurances that they process personal information under suitable data protection arrangements and security controls in place in accordance with the requirements in GDPR and the DPA. These third-party service providers include, among others.
- the National Free Wills Network when you sign up to receive a Free Wills Information Pack, including on the “Free Will Service” page of the UK page on our website. Your name and address will be passed to the National Free Wills Network so that they can send you the requested information. There is no obligation to leave a gift in your will to HSI as part of the Free Will Service. Your Will remains confidential and we will not receive a copy, but the National Free Wills Network will let us know if you have left a gift to us so that we can inform our legacy team and send you a thank you letter. If you would like further information on how your details will be used when you use the Free Will Service, please contact HSI UK’s Legacy team by calling 020 3174 2185 or sending an email to firstname.lastname@example.org.
We also store hard copy material with Telebank in the UK who provide archive services to HSI.
The third-party service providers specifically named above are representational as of the latest update of this notice. Additional and/or alternative third-party service providers may be engaged from time to time with the understanding that we have been provided with assurances from each additional or alternative provider that they process personal information under suitable data protection arrangements and security controls in place in accordance with the requirements in the UK GDPR and the DPA.
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
We will also disclose your information to third parties:
- in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
Where do we store your personal data?
The personal data that we collect from you for all online transactions is transferred to and stored in Canada. All other data is transferred to and stored in the United States. The data may be processed by personnel of HSI or by one of our suppliers/vendors operating outside the United Kingdom. By submitting your personal data, you agree to this transfer, storing or processing outside of the United Kingdom.
From time to time, HSI may link to other web sites not affiliated with HSI. HSI attempts to link only to those web sites which also respect a visitor’s privacy and the goals of HSI. However, HSI cannot be responsible for the content or policies of third-party web sites. Please check with these third-party organizations or companies for their specific privacy policies. If you find inoperable links or are concerned about any of the sites that HSI currently links to, please inform HSI by contacting us at email@example.com, 5 Underwood Street, London, N1 7LY, United Kingdom.
7. How we keep your personal information secure?
HSI uses generally accepted, industry-standard security systems, software, and encryption technologies — Secure Sockets Layer (SSL) — for the secure transfer of personal and financial data and to protect against unauthorised access to HSI servers, equipment, and other components of our online presence. Our web servers are hosted off-site at multiple, physically secure facilities with limited access.
Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.
8. Your rights
Withdrawal of consent
Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by e-mailing us at firstname.lastname@example.org. You may also unsubscribe at any time in every issue of our newsletters.
Objection to marketing
At any time you have the right to object to our processing of data about you in order to send you action alerts of petitions, including where we build profiles for such purposes and we will stop processing the data for that purpose.
If you are in the United Kingdom or in relation to your relationship with the Humane Society International (UK), depending on the information we hold about you and the reason for us holding it, you have certain rights which are set out below. You may have additional rights in relation to the personal data we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by sending us a copy of your passport or driving license. To exercise any of your rights, please email email@example.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.
Access: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
Portability: You have the right to receive a subset of the personal data you provide us if we process it on the bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal data to another party. If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party.
Correction: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed.
Erasure: You may request that we erase the personal data we hold about you in the following circumstances: where you believe it is no longer necessary for us to hold the personal data, we are processing it on the basis of your consent and you wish to withdraw your consent, we are processing your data on the basis of our legitimate interest and you object to such processing, you no longer wish us to use your data to send you marketing or you believe we are unlawfully processing your data.). Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.
Restriction of Processing to Storage Only: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in the following circumstances: you believe the personal data is not accurate for the period it takes for us to verify whether the data is accurate, we wish to erase the personal data as the processing we are doing is unlawful but you want us to simply restrict the use of that data; we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defence of legal claims; and you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
9. How you can complain or contact us
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request. If you are an individual who uses our services in the UK or interact with our UK entity, this is without prejudice to your right to launch a claim with the data protection supervisory authority in the UK where you think we have infringed data protection laws.
If you would like to contact HSI about correcting information we might have collected, or if you have any questions about this privacy notice, please e-mail us at email@example.com, or write to Office of the General Counsel, HSI, at 1255 23rd Street, NW, Suite 450, Washington, DC 20037 USA or at 5 Underwood Street, London, N1 7LY, United Kingdom.