Last updated 24 May 2018
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 organizations 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 organizations include Humane Society International–Europe, a society without a lucrative purpose governed by the law of June 27, 1821 with its registered office at 50 Avenue des Arts, 1000 Brussels, Belgium and registered with the Banque-Carrefour des Entreprises under number 0562.718.279 and 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, Humane Society International–Europe and Humane Society International (UK). Our EU Representative is the Humane Society International (UK), email@example.com.
This privacy notice governs the URL http://www.hsi.org (the “website”) and certain communications sent out by HSI. HSI is the “data controller” of the personal data processed in connection with the website for the purposes of the General Data Protection Regulation (the GDPR) (which applies across the European Union, including the United Kingdom), the Data Protection Act 2018 (the Data Protection Act) which supplements GDPR and extends its application in the UK, and Loi du 3 décembre 2017 portant création de l’Autorité de protection des données, which supplements GDPR and extends its application in Belgium. Personal data is defined in the GDPR as any information relating to an identified or identifiable natural person.
HSI is committed to your right to privacy and to keeping your personal information private and secure. You can visit our web site without telling us who you are or revealing any identifying information about yourself. However, because our web site includes areas in which visitors can provide personally identifying information and because we monitor website usage, we have developed this privacy notice to inform you of our policies and practices regarding information we collect about you.
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 and our communications with them;
- To send our supporters marketing information about our activities, news, action alerts and fundraising where we have their consent or are otherwise allowed to;
- To fulfill contractual obligations entered into with supporters e.g. online donations and purchases;
- To comply with legal obligations;
- To manage our organization; 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 send us an e-mail or complete any of our forms, such as when you request information from us, make a donation, subscribe to one of our online newsletters, or forward a web page, electronic postcard, electronic ballot or electronic newsletter using our “email” function. Depending on how you choose to interact with us, such information may include your name, phone number, mailing address, e-mail address, campaign interests and preferences; it may also include the names and e-mail addresses of those to whom you forward HSI electronic content, and other information collected in the forms. 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 and CVV), however these are provided direct to our authorized 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, Url you are coming from before visiting the Website. HSI.org logs these IP addresses, 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, use first-party and third-party cookies together for re-targetting, where you may see an ad for HSI based on past visits to our website displayed on other sites you visit.
4. Ways information about you is used
The laws on data protection provide a number of different reasons (legal basis) for organizations 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 sending direct marketing information to keep our supporters updated on HSI projects, activities, news and action alerts. 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 twenty-four (24) months.
6. How do we share your personal data?
We do not sell, rent or lease your personal information to others except as described in this privacy notice. We share your information with selected recipients. These categories of recipients include:
- With your consent, we may from time to time make your contact details, including emails but excluding credit card information (which will never be disclosed), available to HSI affiliate organizations or to sponsors or licensees that provide special programs or services we think you might find interesting or beneficial. If your volunteered personal information will be used in any manner other than as stated above, such use shall be specifically posted. If you wish to update or remove your information, or withdraw your consent to your information being shared with affiliated third parties, please e-mail us at firstname.lastname@example.org.
- to advertisers and advertising networks, including Google, that require the data to select and serve relevant adverts to you and others. We use cloud-based providers who operate within the EU under suitable data protection arrangements and security controls in place in accordance with the requirements in GDPR;
- 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. These third-party service providers include:
- 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 authorized card payment providers, including Sagepay, Paypal UK and Paysafe, 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.; and
- analytics services providers, including Tableau and Google, both located in the United States that assist us in the improvement and optimisation of the Website.
We also store hard copy material with Telebank in the UK who provide archive services to HSI.
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.
7. 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/vendor operating outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing outside of the EEA.
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 or firstname.lastname@example.org, 5 Underwood Street, London, N1 7LY, United Kingdom. For more information regarding linking to HSI’s web sites, please read “Linking to HSI.org” on our web site.
8. 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 unauthorized 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 organizational measures to safeguard your personal data against loss, theft and unauthorized use, access or modification.
9. 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 email@example.com or, in in the UK or EU, 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 European Union or in relation to your relationship with Humane Society International–Europe or 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 EU or interact with our UK or EU entity, this is without prejudice to your right to launch a claim with the data protection supervisory authority in the UK or EU country in which you live or work 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 us at Office of the General Counsel, HSI, 1255 23rd Street, NW, Suite 450, Washington, DC 20037 USA or, if in the UK or Europe at firstname.lastname@example.org, 5 Underwood Street, London, N1 7LY, United Kingdom.