Compassion International
‘Beneficiary Photos’ App - Privacy Policy
Last Revised: 05/28/2024
Our
Commitment
Compassion
International is committed to your privacy. We value your trust and want
to assure you that we will always strive to be responsible in our management of
your personal information.
We provide
this Privacy Policy to make you aware of our privacy practices, and to inform
you about the way your information is collected and used. We commit that any
activity we engage in with your information is ultimately for the greater
purpose of helping to release children from poverty in Jesus’ name.
If you have questions or concerns, please
contact us at (800)
336-7676, Monday through Friday, 7a.m. to 5:30p.m. MT
or a or via email.
To learn more about our commitment to
protecting the privacy of children in our program visit https://www.compassion.com/how-we-work/commitment-child-protection.htm
Privacy Policy
This Privacy
Policy describes how ‘CI FCP’ a group within Compassion International (collectively,
“Compassion,” “we,” “us,” or “our”) collects, uses, shares, and safeguards
personal information within the mobile app, ‘Beneficiary Photos’. This Privacy Policy also tells you about your choices with respect to your
personal information, and how you can reach us to get answers to your
questions. You can jump to particular topics by going to
the headings below:
Types of Information We
Collect
Use and Processing of
Information
Cookies and
Similar Technology
Your Choices
How We Protect Personal
Information
Miscellaneous
Conditions of
Use
Types of Information We Collect
The following
provides examples of the type of information that we collect from you and how
we use that information.
|
Context |
Types of
Personal Information |
Primary
Purpose for Collection |
Is Personal
Information Shared for Targeted Advertising? |
|
Account Registration and Information |
We collect your email address when you create an
account. We also collect information
relating to the actions that you perform while logged into your account. |
We use the personal information for our legitimate
interest and with your consent to better serve you to provide account related
functionalities to our users. Accounts can be used for easy access to
resources and to save your preferences and account history. |
No |
|
Feedback/Support |
If you provide us feedback or contact us for support,
we will collect your e-mail address, as well as any other content that you
send to us, in order to reply. |
We have a legitimate interest in receiving, and acting
upon, your feedback or issues. |
No |
|
Photo Information |
We may collect photographic information that you submit
via the app. |
We have a legitimate interest to process photographic
information where that media is an applicable part of the Compassion
International participant sponsorship program. Do not submit photos that are not related
to this program. |
No |
|
App Interactions |
We use 3rd party analytics technology to
monitor and record how you interact with our app. This includes tracking your
usage of the app and errors that may occur. |
We use this information to understand how you interact
with our app, to improve it, and to understand your preferences and interests
in order to select offerings. We also use it to detect and prevent abuse.
These are all our legitimate interests. |
No |
Please note,
if you fail to provide certain personal information when requested, we may not
be able to complete certain transactions or perform obligations that we have to
you (such as facilitating your participation in Compassion programs.)
In addition
to the information that we collect from you directly, we also receive
information about you from other sources, including third parties, business
partners, our affiliates, or publicly available sources
To learn more about our commitment to
protecting the privacy of children in our program visit https://www.compassion.com/how-we-work/commitment-child-protection.htm
Use and
Processing of Information.
In addition to the purposes and uses
described above, we use information in the following ways:
·
To identify you when you use our application.
·
To improve our services and support our
mission.
·
To conduct analytics.
·
To respond to inquiries related to support, or other
requests.
·
To create and steward effective partnerships
with churches and volunteers.
·
For internal administrative purposes, as well as to
manage our relationships.
Although
the sections above describe our primary purpose in collecting your information,
in many situations we have more than one purpose. As a result, our collection and processing of
your information is based in different contexts upon your consent, our need to
perform a contract, our obligations under law, and/or Compassion’s legitimate
interest.
To the extent we maintain and use personal
information in a deidentified form, we will not attempt to reidentify the
information, except for the purpose of determining whether our deidentification
processes satisfy our legal obligations.
Sharing of
Information.
We may disclose information to third parties,
including service providers, partners, individuals and other third parties, for
various reasons. The table below describes the categories of personal
information we collect and the categories of third parties to whom we disclose
such personal information. We do not sell your personal information, nor
do we participate in any sharing that would constitute a sale under applicable
law.
|
Category of Personal Information |
Category of Recipients |
|
Contact information – such as your first
and last name, or email address, |
· Data analytics providers · Communications providers · Partners |
|
Other identifiers – such as IP address or
other online identifiers. |
· Data analytics providers · Communications providers · Partners |
|
Photographic Information |
· Data analytics providers · Other Service Providers · Communications providers · Partners |
|
Internet or other electronic network
activity information – this may include browsing history, search history, and
information regarding an individual’s interaction with an internet website,
application, or advertisement. |
· Data analytics providers · Internet service providers · Operating systems and platforms · Other Service Providers · Communications providers |
|
Geolocation data |
· Data analytics providers · Other Service Providers · Communications providers · Partners |
|
Inferences drawn from any of the
information listed above |
· Data analytics providers · Other Service Providers · Communications providers · Partners |
In addition to the specific situations discussed elsewhere in this
policy, we disclose information in the following situations:
1.
Affiliates. We share information with Compassion
affiliates (e.g., international
Compassion entities).
2.
Other Disclosures with Your Consent. We may ask if you would like us to share your
information with other unaffiliated third parties who are not described
elsewhere in this policy.
3.
Other Disclosures without Your Consent. We
disclose information in response to subpoenas, warrants, or court orders, or in
connection with any legal process, or to comply with relevant laws. We may also share your information in order
to establish or exercise our rights, to defend against a legal claim, to
investigate, prevent, or take action regarding possible illegal activities,
suspected fraud, safety of person or property, or a violation of our policies,
or to comply with your request for the shipment of products by or the provision
of services by a third party intermediary.
4.
Public. Some
of our websites provide the opportunity to post comments, or reviews, in a
public forum. If you decide to submit
information on these pages, that information may be publicly available.
5.
Service Providers. We share your
information with 3rd party service providers. Among other things service providers help us
to administer our website, conduct surveys, provide technical support, conduct
analytics, improve our services, facilitate events, and process payments.
Your Rights and Choices.
Compassion
provides all rights to your information that are required by law. In any case, Compassion will consider all
requests from individuals regarding their personal information. These requests may include:
1.
Access to Your Personal Information. You
may request access to your personal information or confirmation that we have
information about you by contacting us at the address described below. In
certain limited circumstances, you may also request to receive access to your
data in a portable, machine-readable format. If required by law, upon request,
we will grant you reasonable access to the personal information that we have
about you.
2.
Changes to Your Personal Information. We
rely on you to update and correct your personal information. Our website allows you to modify your account
profile. You may also contact us at the
address described below in order to request that your
information by modified. Note that we
keep historical information in our backup files as permitted by law.
3.
Deletion of Your Personal Information. You
may request that we delete your personal information by contacting us at the
address described below. If required by
law we will grant a request to delete information, but you should note that in
many situations we must keep your personal information to comply with our legal
obligations, resolve disputes, enforce our agreements, or for another one of
our business purposes.
4.
Online Tracking. We do not currently recognize "Do Not
Track" instructions.
5.
Objection to or Restriction of Certain Processing. In
certain scenarios and in certain jurisdictions, you can object to our processing
of your personal information, or request that we restrict processing of your
personal information, by contacting us at the address described below.
6.
Promotional Emails.
You may choose to provide us with your
email address for the purpose of allowing us to send materials to you. You can stop receiving promotional emails by
following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional
emails, we will still send you service-related communications.
7.
Text Messages. To
discontinue SMS text messages from Compassion, text STOP to 97646. To learn
more about SMS Terms and Conditions visit https://www.compassion.com/sms-terms-and-conditions.htm
8.
Revocation of Consent. You
may revoke consent to processing (where such processing is based upon consent)
by contacting us at the address described below. If you revoke your consent for the processing
of personal information, then we may no longer be able to facilitate a child
sponsorship for you or provide you with other services.
9.
Opt-out of Targeted Advertising. You may opt-out of targeted advertising by
contacting us at the address listed below. If you are a Colorado resident, you
may have an authorized agent submit a request on your behalf by having them
contact us at the address described below.
Please note, not all of the
rights described above are absolute, and they do not apply in all
circumstances. In some cases, we will limit or deny your
request if the law permits or requires us to do so, or if we are unable to
adequately verify your identity. We will not
discriminate against individuals who exercise their privacy rights under
applicable law.
Note that, as required by law, we will require you to
prove your identity. We may verify your
identity by phone call or email. Depending
on your request, we will ask for information such as your name, address, phone
number, account number and/or billing information. We may
also ask you to provide a signed declaration confirming your identity.
If you disagree with our denial of a request, you may
appeal our decision by contacting us as indicated in the “Contact Information”
section below with the subject line “Appeal.”
How We Protect and Retain Personal Information
No method of transmission over the Internet,
or method of electronic storage, is fully secure. While we use reasonable efforts to protect
your personal information from unauthorized access, use, or disclosure, we
cannot guarantee the security of your personal information. In the event that we
are required by law to inform you of a breach to your personal information we will
notify you electronically, in writing, or by telephone, if legally permitted.
Some of our websites and applications permit you to create an
account. When you do you will be
prompted to create a password. You are
responsible for maintaining the confidentiality of your password, and you are
responsible for any access to or use of your account by someone else that has
obtained your password, whether or not such access or
use has been authorized by you. You
should notify us of any unauthorized use of your password or account.
We retain your personal information for only as long as necessary to
fulfil the purposes outlined in this Privacy Policy, including for the purposes
of satisfying any legal, accounting, or reporting requirements, unless a longer
retention period is required or permitted by law. To determine the appropriate retention period
for personal information, we consider the amount, nature, and sensitivity of
the information, the potential risk of harm from unauthorized use or disclosure
of the information, the purposes for which we obtained the information and
whether we can achieve those purposes through other means, as well as
applicable legal requirements.
Miscellaneous
The following additional information relates
to our privacy practices:
·
Transmission of
Information to Other Countries. Your information may be
processed in a foreign country where privacy laws are less stringent than the
laws in your country. By submitting your personal information to us you agree
to the transfer, storage, and processing of your information in a country other
than your country of residence, including, but not necessarily limited to, the
Unites States. Compassion utilizes
Standard Contractual Clauses as an adequacy measure for data transfers from the
European Union.
·
Third Party Applications/Websites. We
have no control over the privacy practices of websites or applications that we
do not own. In doing so you may be
required to provide personal data to such third-party applications and in those
cases, the privacy policies and terms of the third
party will apply to the processing.
·
Changes to This Privacy Policy. We may
change our privacy policy and practices over time. To the extent that our Privacy Policy changes
in a material way, the policy that was in place at the time that you submitted
personal information to us will generally govern that information unless we
receive your consent to the new privacy policy.
We will note the effective date of the latest version at the beginning
of the Privacy Policy.
Contact Information. If you have any questions,
comments, or complaints concerning our privacy practices or conditions of use,
or if you need to access this Privacy Policy in
an alternative format due to having a disability, please contact us at the
appropriate address below. We will
attempt to respond to your requests and to provide you with additional
privacy-related information.
Compassion International
12290 Voyager Parkway
Colorado Springs, CO 80921
If you are not satisfied with our response
and are in the European Union or the United Kingdom, you may have a right to
lodge a complaint with your local supervisory authority.
***If you
have questions or want to exercise your data subject rights, or opt-out of
targeted advertising, please contact our Data Protection Officer at [email protected]. ***
Children’s Data
Outside of our programs for children, we do
not intentionally collect information about or from children.
We do not intend to collect personal
information from children under 18 who are not part of our program. If you are a parent or legal guardian and
think your child under 18 has given us personal information, contact us at (800)
336-7676, Monday through Friday, 7 a.m. to 5:30 p.m.
MT or via email. Parents,
you can learn more about how to protect children's privacy online here (https://consumer.ftc.gov/identity-theft-and-online-security/protecting-kids-online).
Effective Date: 05/28/2024