Last Updated: Oct 22, 2024
Welcome to the website (“Site”) of RefugePoint (“RefugePoint”, “we”, “us”, or “our”). RefugePoint’s mission is to partner with refugees to access life-changing solutions and transform how the world supports them. This Website Visitor Privacy Notice describes how RefugePoint handles personal information that we collect through our website https://www.refugepoint.org/ or through any other websites that we own or control, including any services provided through the websites (collectively, “Services”).
RefugePoint also has a Donor Privacy Notice, which provides specific information regarding how we handle your data when you make a donation.
- Contact information, such as your first and last name, phone number, and email address that you may provide to us, for example if you subscribe to our newsletter.
- Feedback, communications or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us.
- Data that you provide when you enter into agreements with us. When you enter into a contractual agreement with us (for example, as a corporate partner, program partner or supplier) we may collect certain details in respect of you or other representatives of your business or organization, such as name, contact details, company details, title, job function and address/location.
- Donation information – Please see our Donor Privacy Notice for specific information regarding how we handle your data when you make a donation.
- Other data not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed at the time of collection.
Information we obtain from third parties: We may maintain pages on social media platforms, including but not limited to Facebook, Instagram, LinkedIn, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information.
We and our service providers may automatically log information about you, your computer or mobile device, and your interactions over time with our Site, our communications and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.
We use the following tools for automatic data collection:
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- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand website user activity and patterns. We use cookies and similar technologies to operate and administer our Site, make it easier for you to use the Site during future visits, gather usage data on our Site, and for advertising purposes.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
- To provide, operate, and maintain and secure our Services – It is in our legitimate business interests to use personal information to operate, maintain, and provide you with our Services, including ensuring you can use our Site. If we have entered into a contract with you, we will use your personal information as required for us to perform our contractual obligations under the relevant contract.
- To communicate with you about our activities and Services – To perform our contractual obligations to you, or when it is in our legitimate interests to do so, we will use your personal information to respond to your requests, questions and feedback, and communicate with you about our Services, including by sending you announcements, security alerts, support messages, and administrative messages.
- To improve, monitor, and personalize the Services – It is in our legitimate business interests to improve and maintain the quality of our Services, including by understanding your needs and interests, and personalizing your experience with the Services and our communications.
- For research and development – We may use your personal information for research and development purposes in our legitimate business interest to analyze and improve our Services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and disclose it to third parties for our lawful business purposes, including to analyze and improve our services and promote our business.
- Direct marketing – We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, newsletters, program updates, information about new ways to support RefugePoint’s work, and events via email. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us your personal information. Otherwise, we will only send you marketing information if it is in our legitimate business interests to send such information.
- Interest-based advertising – We engage our advertising partners, including third-party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information about your interaction over time across our Site, our communications, and other online services, and use that information to serve online ads that they think will interest you. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Online tracking opt-out” section below. Where required by law, we will only engage in these advertising activities if you consent to us doing so at the time you provide us your personal information. Otherwise, we will only do so if it is in our legitimate business interests.
- Compliance and protection – We may use personal information to comply with legal obligations and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to enforce any applicable terms and conditions, protect the security and integrity of our business, and identify and investigate fraudulent, harmful, unauthorized, unethical or illegal activity.
- Service providers – We may disclose your personal information to third party companies and individuals that provide services on our behalf or help us operate our services (such as lawyers, bankers, auditors, insurers, website support, hosting, analytics, email delivery, marketing, and database management).
- Authorities and others – We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
- Business transfers – We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Notice.
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, any permissions you give us with regards to your personal information, and the applicable legal and regulatory requirements.
Opt out of receiving general communications from RefugePoint by updating email communication preferences, which can be found in the footer of all RefugePoint email communications.
Online tracking opt-out. There are a number of ways to limit online tracking, which we have summarized below:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.
- Using privacy plug-ins or browsers. You can block our Site from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:
- Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Under certain circumstances, you have rights under the data protection laws in relation to your personal information:
- Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Notice.
- Access to a copy of the personal information that we have collected about you (commonly known as a ’data subject access request’). Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need for lawful purposes.
- Additional rights, such as to object to and request that we restrict our use of personal information.
- Appeal our denial of your personal information request.
You may submit these requests by email to info@refugepoint.org or our postal address provided below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
Choosing not to disclose your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.
We may transfer your personal information and/or store it on servers outside your local jurisdiction. Where personal information is transferred outside the United Kingdom and European Economic Area, such as to the United States, we take legally required steps to ensure that adequate safeguards are in place to protect your personal information (for example, relying on the European Commission/UK Government approved standard contractual clauses to govern the transfers of personal information). You can request more information about the safeguards that we have put in place to protect your personal information in these circumstances by contacting: info@refugepoint.org.
Our Site may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and disclosure of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
Our Site is not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Site from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
We reserve the right to modify this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on the Site.
Please direct any questions or comments about this Notice or our privacy practices to info@refugepoint.org or by post to:
RefugePoint
89 South Street, Suite 802
Boston, MA 02111
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Privacy Policy
