1) INTRODUCTION

In this document, we describe how we manage the website www.animalsasia.org (hereinafter "Website") with reference to users personal data processing. The Website is managed by Animals Asia Foundation e.V. Eversheds Sutherland (Germany), with legal office in Brienner Str. 12, 80333 München, Deutschland (hereinafter "we", "us", "our").

When you browse our Website, you interact with us or use our services ("Services"), we can collect information and personal data about you. For this reason, in accordance with the provisions of Regulation (EU) n. 2016/679, the General Data Protection Regulation ("GDPR"), we created the following document (hereinafter "Privacy Policy") in order to describe to you the personal data that we collect, the purposes and methods of data processing and the security measures we implement to protect them.

This Privacy Policy constitutes the information provided pursuant to Articles 13 et seq. GDPR and to national data protection laws and it concerns exclusively the Website and the data processing by us. Any third-party websites referred to on this Website, including through links, are not covered by the information indicated in this Privacy Policy.

2) WHO PROCESSES YOUR DATA?

On this Website, the data controller is Animals Asia Foundation e.V. Eversheds Sutherland (Germany), with legal office in Brienner Str. 12, 80333 München, Deutschland, email address: [email protected].

3) WHICH DATA DO WE PROCESS?

• Navigation data: The information systems and software procedures relied upon to operate this Website collect personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. This information is not gathered to be associated with identified subjects but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used to connect to the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user's IT environment. These data are used for the purpose of obtaining statistical information on the use of the Website and to check its correct functioning and they are deleted in line with the requirements of applicable law. The data could be used to ascertain responsibility in case of possible criminal actions or damages against the Website only to the extent permitted by applicable law.
• Data collected via cookies and other similar technologies: Subject to your prior consent when required under applicable law, our Website uses cookies and other similar technologies; for more information visit our Cookie Policy.
• Identification data, contact details and other personal information: When you contact us using the "Contact us" form on the Website, we collect your title, name and surname, your email address and/or your other contact details such as telephone number or physical address, and the content of your request, all of which is necessary for us to respond to your message. If you collect, process and communicate to us information of third parties, you will need to do so in accordance with the provisions of the GDPR and, therefore, you will need to give the third parties prior information on the purposes and methods of processing and, if necessary, you will need to collect their consent before carrying out the processing activity.

Through our Website you can also create a personal account; to open your personal account, you will be asked to provide your title, name and surname, your email address, your physical address, your username and a password. Through your account, you can keep track of your donations, view your giving history and update your information.

Furthermore, your email address will be processed when you decide to subscribe to our newsletter or other emails we send. As well as the interaction with these emails such as whether the emails were opened or any of the linked were clicked on.

Specific summary information notices will be progressively reported or displayed on the Website pages set up for particular services on request.

• Data collected when you make donations through our Website: When you make single or recurrent donations through our Website, we collect information regarding the donation (such as date, amount, currency) and the details of your donation, such as data regarding the payments methods that you use, the address indicated for the receipt, the details necessary to provide you with the relevant fiscal documentation, the wire-transfer costs.
• Data collected when you make donations through our leaflets: When you make single or recurrent donations through our leaflets, we collect information regarding your name and the details of the donation you make, as well as the details of the method of payment you choose.

 4) WHAT ARE THE PURPOSES OF THE DATA PROCESSING?

We process your personal data for the following purposes and we indicate the respective legal bases:

• To manage and operate our Website, to improve it and to solve potential problems. Processing is based on our legitimate interest in presenting our activities to the public, ensuring the functioning of the Website, improving its appearance and user experience.
• To get to know our users. The use of cookies and similar technologies allows us to recognize you when you return to our Website and to analyse your online activities, subject to your prior consent, as applicable. For more information, visit our Cookie Policy.
• To allow you to create your personal account on our Website. To allow you to create your personal account we process the information indicated above, such as your name and surname, contact details and address. The processing is based to the necessity to comply with your request to have an account on our Website. Provision of your personal data is necessary. In failure, it may not be possible for us to create your account.
• To process your donations and to comply with applicable laws related to donations.When you donate through our Website or our leaflet, we process the information necessary to accept your payment and comply with our subsequent obligations, such as to send you the relevant receipt and fiscal documents. We process your personal data also to comply with the applicable laws on donations. The processing is based on the performance of a contract with you, including the fulfilment of any requests you made, and on the compliance with applicable laws. Provision of your personal data is necessary; in failure it may not be possible for us to accept a donation from you.
• To send you newsletters. When you subscribe to the newsletter, we use your email address to send you communications to you, such as news and updates on our campaigns and activities, including surveys and invites to events organized by us or in which we take part. Failure to provide your data does not affect your ability to browse our Website or send donations through it. You can withdraw your consent with future effect at any time by sending us an email at the addresses indicated above or by using the link offered on the bottom of each newsletter you receive.
• To send you information and answers to your requests. You can send us messages and requests through the forms on our Website or by writing directly to us; we use your information to answer your requests. Processing is based on the performance of the contract with you, including the fulfilment of any requests you made or on our legitimate interest to respond to your messages or requests. Failure to provide your data may make it impossible for us to fulfil your requests.
• For research purposes. To conduct and/or fund research into Animals Asia programs and services or research into supporter attitudes.
• For analysis, targeting and segmentation. This allows us to gain a deeper insight into our supporters, so we are able to send marketing which is tailored and relevant.

The information used could be your preferences, interests, and capacity to give financially in order to establish whether any of our supporters has the potential to give for the first time or to give more. This may be by desk research, profiling and screening techniques to analyse your personal information so we can build a profile to contact you with relevant information, to be prepared when we meet you, or to help us find other people like you who might like to show their support. In certain instances, we may add publicly available information to our analysis - for example addresses, information from government registers, newspaper and web articles, social media posts, or typical earnings in an industry. This helps to give us a fuller picture of who supports Animals Asia and whether it is appropriate to make an approach for increased giving, or to work out whether it would be appropriate to ask someone to consider leaving us a legacy. This helps us to make appropriate and relevant approaches and target our resources more effectively. Animals Asia may also use geo-demographic information and measures of affluence to tailor asks accordingly. We may on occasion use third party suppliers (some examples are: Factary, or Prospecting for Gold or Wealth-X or Experian Mosaic) to provide us with the aforementioned profiling information and we would only provide them with the elements of data we hold about you to make this task possible.

• Email tracking. We also carry out email tracking such as when an email has been opened or when links were clicked on. This allows us to measure whether our email communications are successful and to tailor future emails accordingly

The provision of your data is neither a statutory nor a contractual requirement. You are not obliged to provide us with your data, however, failure to do so may prevent you from using all features of the Website or the full range of our Services.

5) HOW DO WE PROCESS YOUR DATA?

Your personal data can be processed with electronic and paper-based means.

The security of your personal data is important to us. We adopt - and we require our service providers to adopt - adequate technical and organizational security measures to prevent data loss or destruction, even accidental, unlawful, or incorrect uses and unauthorized access to data, in compliance with applicable laws. Furthermore, IT systems are set in a manner that allows to use personal and identification data only if necessary to achieve specific processing purposes.

We implement multiple technologies and security procedures to protect personal data from the risks described above.

However, we would like to remind you that electronic transmission and information storage are not 100% safe. Therefore, we are not able to guarantee that loss, misuse or alteration of the data will never occur, despite the security measures we implement to protect your personal data.

We may also use your email address and telephone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in Animals Asia, and we may then show them Animals Asia content. We only do this where you have given your consent to receive marketing emails, or have not opted out of receiving telephone calls, and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.

There are two ways to prevent this use of your data, you can either update your preferences at Animals Asia by opting out of email and telephone marketing or you can do this via the social media site:

Facebook: https://www.facebook.com/help/568137493302217

LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931

Twitter: https://business.twitter.com/en/help/troubleshooting/how-twitter-ads-work.html

Updating your preferences with Animals Asia will not guarantee that you never see Animals Asia content on social media, since the social media site may select you based on other criteria and without your data having been provided by Animals Asia.

We do not use automated individual decision-making that would produce legal effects for you or would similarly significantly affect you.

6) HOW LONG DO WE PROCESS YOUR DATA?

Personal data is processed for the time necessary to provide the requested information or Services, in compliance with any applicable legal or regulatory obligations.

Notably, in case of subscription to our newsletter, we process your personal data until your possible withdrawal request or your objection to the processing.

When you send a communication or a request to us, we process your personal data for the time necessary to reply to your question or provide the requested assistance.

We will retain all data related to your donations, for fiscal and tax purposes, for the time necessary to comply with the applicable laws. The most important legal retention obligations for us result from Sec. 257 of the German Commercial Code (HGB) and Sec. 147 of the German Fiscal Code (AO) and are for six and ten years respectively. Unless we have a legitimate interest to keep the data for a longer period.

You can exercise your rights at any time, including the right to delete your data. More information is provided in section 8 below. For further information on the retention of cookies and similar technologies, please visit our Cookie Policy.

7) TO WHOM DO WE COMMUNICATE OR TRANSFER YOUR DATA?

Our authorized staff, according to respective needs, will process your personal data. Furthermore, your data will be processed by our suppliers for technical and organizational services functional to the processing purposes stated above, such as for example suppliers of technical assistance services for the Website; suppliers of hosting services; suppliers of services for the multiple sending of marketing communications; suppliers of documents and data archiving services. These parties act as our data processors based on our instructions and on the agreements signed with us.

We might disclose your personal data to authorities or public bodies and to any other legitimate recipient pursuant to the law. In this case, the recipients will act as autonomous data controllers according to their respective institutional purposes.

If we reorganize, acquire, or sell our company or branches of it, we will communicate your personal data to the third parties involved in the procedure, as permitted under applicable law. During said procedure, any third-party recipient of your personal data might only use them within the limits established by this Privacy Policy and applicable law.

To receive the updated list of your personal data recipients you can contact us at the contacts indicated above.

In case of transfer of your data abroad to foreign countries that do not guarantee the same level of data protection as in your home country, we will ensure that the transfer is carried out in compliance with the provisions of applicable laws, i.e. through the collection of your consent, when necessary, or through the adoption of any other measure necessary to ensure an equivalent protection of transferred data, including, without limitation, by concluding standard contractual clauses according to European Commission template. If you would like to receive a copy of these safeguards, please contact us through the contact details indicated in section 2 of this Privacy Policy.

 8) WHAT RIGHTS DO YOU HAVE AN HOW CAN YOU EXERCISE THEM?

Pursuant to - and subject to certain restrictions under - applicable personal data protection law, you can request to access your personal data, to verify its accuracy or to ask its rectification or update at any time.

You can also request to erase your personal data, as well as to limit your data processing in the cases provided by the law.

You can object to the processing of your data on grounds relating to your particular situation, at any time, unless for the existence of compelling legitimate grounds of processing by the data controller or as otherwise restricted under applicable personal data protection law. The right to object to the processing of personal data can be exercised at any time in cases of processing for direct marketing purposes.

You can also request portability of your data, and receive such data in a structured format, commonly used and machine-readable, and you can request that your data be transferred to another data controller without any obstruction from our part.

Finally, you can withdraw your consent to the processing of personal data at any time and you can also exercise all other rights provided to you under national data protection laws.

To exercise your rights you can contact us through the contact details indicated in section 2 of this Privacy Policy to exercise the abovementioned rights.

Lastly, you can lodge a complaint with the competent supervisory authority or contact the authority if the exercise of your rights is subject to delay, limitation or exclusion by the data controller. The contact details of the national supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

9) CHANGES TO THIS PRIVACY POLICY 

We may update and modify this Privacy Policy completely or in part at any time. The version published on the Website is the last updated and currently in force. In case of modification of this Privacy Policy, we will inform you through a special banner, link or pop-up on the home page of the Website or through a dedicated email.