Privacy Policy

Swabhiman respects your privacy. We collect information to provide services to you, update you on the impact of your contributions, and communicate about and in relation to our Services. We understand our responsibility and commit to maintaining and protecting the integrity of your personal information collected by us.

Overview

This privacy policy (“Privacy Policy”) is for you to know how we look after your Personal Data (defined hereinafter) and what are your privacy rights. This Privacy Policy applies to every user accessing or using the services on the Website. You can refer to Terms of Use to understand the meaning of some of the terms used but not defined in this Privacy Policy.

Our Privacy Policy is in compliance with General Data Protection Regulation (“GDPR”).

By continuing to access or use Swabhiman’s website (“Website”), you agree to be legally bound by this Privacy Policy and the Terms of Service.

This Privacy Policy serves as a supplementary agreement to the Terms of Use. This Privacy Policy, the Terms of Use, and its other supplementary agreements may be modified from time to time, at our sole discretion, when the need is felt, to accommodate for the changes in our Services or the law applicable to us. Such changes shall be reflected on our Website. We advise you to check for the last revised date given at the end of the Privacy Policy.

This policy applies to information collected by Swabhiman through all channels including but not limited to the Website, including online and offline Donations.

1. Data Collected

1.1 Personal data (“Personal Data”), or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data where the identity has been disassociated with the data.

1.2 The Website is not intended for children and we do not knowingly collect any data relating to children.

1.3 We may collect, use, store and transfer different kinds of your Personal Data such as:

1.3.1 Identity Data such as your first name, middle name, last name, username or any other similar identifier, gender, date of birth, your language, home address and nationality;

1.3.2 Contact Data such as your email address, phone number or telephone number;

1.3.3 Transaction Data such as your payment card or cheque details, details about payments to and from you, details of Services availed, or Donations made or received by you;

1.3.4 Technical Data such as your geo co-ordinates, your login data, browser and device details, time zone setting, browser plug-in types and versions, operating system and other technology on the devices you use to access the Website;

1.3.5 User Account Data such as your username and password, your interests, preferences, feedback and responses; and

1.3.6 Marketing and Communications Data includes your communication and advertisement preferences.

1.4 We also collect, use and share aggregated data such as statistical or demographic data for certain purposes. These aggregated data may be derived from your Personal Data but is not considered Personal Data under law as this data in no way reveals your identity. Such data is used for statistical purposes to improve our understanding of our audience and consequently, better our Website and Services.

1.5 If we ever combine or connect aggregated data with your Personal Data, we shall treat such data as Personal Data and use it in accordance with our Privacy Policy.

1.6 We only collect Personal Data that is reasonable or necessary for us to meet the purpose of our interaction with you. We do not ask for any immaterial or secondary data about you such as your race or ethnicity, religious, political or philosophical beliefs. If you believe any information being asked is irrelevant or if you have a reason to doubt its relevance, you can inquire about the same by sending us an email.

1.7 Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide such data when requested, you may not be able to engage in certain activities on the Website. However, we will notify you in such a case.

2. Modes of Data Collection

2.1 We use different methods to collect data from and about you including through:

2.1.1 Direct interactions: You may provide us with your identity and contact information while using our Website. This includes Personal Data you provide when you create a user account, subscribe to our updates and newsletters, request to receive advertisements, enter a competition, promotion or survey, provide feedback, fill out an application or make a Donation;

2.1.2 Automated technologies or interactions: When you interact with the Website, it collects your Personal Data by using cookies, server logs and other similar technologies. As a visitor to our Website, Swabhiman's servers automatically record certain information, such as Technical Data and other information about how you interacted with our Website, which can be used to identify you. We may collect this information also through the use of cookies or other tracking technologies (refer to Cookie Policy); and

2.1.3 Third parties or publicly available sources: We may receive Personal Data about you from various third parties and public sources as your Technical Data from analytics providers, advertising networks, search information providers, your Transaction Data from payment, delivery and technical services, your Identity Data and Contact Data from your social networking accounts.

3. Use of Data

3. Swabhiman uses the Personal Data that you provide or we collect, and the technical information logged by our servers to:

3.1.1 Process your Donations or contact you regarding any questions related to your Donation. Use of this data is necessary in relation to processing your Donation;

3.1.2 Comply with our legal obligations (for example, we are required to pass relevant data to the Ministry of Home Affairs or other competent authorities);

3.1.3 Update you on how your Donations have been used, newsletters, our upcoming projects, events, matching opportunities which we think may be of interest to you. We will only send you this information by email with your prior consent to us for doing so at the time you provide us with your Personal Data. You may opt-out of receiving such emails by unsubscribing to them; and

3.1.4 Serve Legitimate Interests. Legitimate Interests refers to our interests in conducting and managing our Services to provide you with the best and most secure experience. We make sure to consider and balance your rights before we process Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests can possibly override your rights, unless you have expressly consented to otherwise or if permitted to us by law. Such activities include notifying your friends and family about your Donations in their honour if you ask us to, anonymising the information that we collect and use for statistical purposes, and compiling aggregate statistics that allow us to understand the patterns of use of our Website and help us to make improvements in design and content so we can improve your experience.

4. Disclosure of Personal Data

4.1 We will share your Personal Data with our agents, representatives, service providers, affiliates and contractors in order to process your Donations, offer you Services in connection with our Website, communicate information and updates in relation to Swabhiman, notify about the project(s) you choose to support with your Donations, claiming, marketing and advertising, and complete financial transactions. These service providers are authorized to use your Personal Data only for the purpose the formation is shared with them, or as otherwise authorized by the Privacy Policy. We shall not trade, share, or sell a Donor’s Personal Data with anyone else except for the purposes mentioned hereinafter.

4.2 We may also be required to disclose your Personal Data in the following circumstances:

4.2.1 In cases we need to cooperate with government and law enforcement agencies or any third parties by an order under the law;

4.2.2 In cases demanded or requested by any tax authority;

4.2.3 If an emergency situation requires disclosure before your permission can be obtained, for instance, situations involving potential threats to the personal safety of anyone; or

4.2.4 When, as determined by us, disclosure is needed to protect our rights or property, or the rights or property of another person, in which case we shall implement appropriate safeguards to ensure that your Personal Data continues to be protected.

4.3 Kindly note that the Website can be accessed from anywhere in the world and Website will have users from all over the world and therefore government, judiciary or law enforcement authorities in various parts of the world may assume or have actual jurisdiction over us or the Website and we may be subject to the laws, rule, regulations and judgments of various countries, states, municipalities or province where we may not have a physical presence.

4.4 You acknowledge that governmental or law enforcement authorities in the countries where your data or information is stored may have the right to decrypt, collect, monitor or access to your data or information which are actions completely out of our control. We do not take any responsibility or liability for such actions.

5. Your Rights

5.1 The European Union (“EU”) GDPR has provided the rights mentioned hereinafter to the EU residents:

5.1.1 Right to access: You can access your account information or make changes or updates at any time by going to your user account/requesting through email). We try our best to keep your data accurate and up to date in our records, to the extent that you provide us. If your data changes, for instance, if you have new contact details, then you are responsible for notifying us of those changes timely.

Upon request through an email to us, we shall provide you with a copy of your information that we have with us;

5.1.2 Right to erasure: If you wish to delete your account or have your information removed from our system, you can do so by sending an email to us. For privacy and security reasons, such requests must come from the email address that you have previously provided us;

5.1.3 Right to rectification: In case your Personal Data is inaccurate or incomplete, you have the right to request us to correct or complete it. If we had shared your Personal Data with others, we shall make sure such changes are reflected in the shared information as well, where possible, to avoid inconsistency. You can ask us, where possible and lawful to do so, to tell you with whom we have shared your Personal Data so you can directly contact them;

5.1.4 Right to restrict processing: You have the right to ask us to restrict or block the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (refer to your right to object discussed hereinafter). We will inform you before we lift any restriction on  processing in such a case;

5.1.5 Right to data portability: You have the right to obtain your Personal Data from us that you consented to provide us or that was provided to us as necessary for the purpose of availing the Services. We will give you your Personal Data in a format comprehensible and clear for you to understand;

5.1.6 Right to object: If we are relying on any of our Legitimate Interests to process your Personal Data (except in cases where processing is necessary) or if we are processing your Personal Data for direct marketing, you have the right to ask us at any time to stop processing your Personal Data, and we shall comply with your request;

5.1.7 Right to withdraw consent: You have the right to withdraw your consent at any time in cases where we rely on your consent to process your Personal Data, but this shall not affect any processing of your data that has already taken place;

5.1.8 Right to lodge a complaint: If you have a concern about our privacy practices, including the way we handle your Personal Data, you can report it to the Information Commissioner’s Office (ICO) or other authorized data protection authority.

5.2 You may ask us to change the anonymous settings on your past Donations by asking us at the aforementioned email address.

6. Third-Party Activities

6.1 Other websites, including those of our partners, the links to which appear on the Website, have their own privacy policies. When you provide Personal Data at one of those websites, you are subject to their privacy policy, not our Privacy Policy. Kindly note that certain of their activities can potentially be managed by users themselves, for example, through the settings of their internet browser and handheld app controls. We encourage you to read the privacy policy of such third parties before submitting any Personal Data to them. You are further advised to take additional steps to safeguard your Personal Data online.

7. Advertising Policy

7.1 Swabhiman aims to raise Donations and help as many people as it can by showing advertisements to people across the world. Usually, our Beneficiaries do not have a strong social media reach and are consequently unable to raise funds online without the help of ads. Ads often help us to reach out to people like you and help those in need.

7.2 We may use the help of third-party advertising technologies. The ads you see may be based on various factors such as the content of the page that you are visiting, your demographic data, User Contribution, and other information that we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored depending on your interests.

7.3 We neither have access to, nor does this Privacy Policy govern the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other devices that you use to access our Website by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may or may not offer you a way to opt-out of ad targeting and we have no control over that, in any way.

7.4 You acknowledge that to the extent advertising technology is integrated into our Website or other websites that you visit, you may still receive advertisements even if you opt-out of it.

8. Data Retention

8.1 We shall retain a Donor’s information for as long as necessary to fulfil the purpose for which it was collected and processed. We may also retain and use your Personal Data in order to comply with our contractual or legal obligations, audit requirements, resolution of disputes, and reporting obligations.

8.2 In order to determine the appropriate duration for retention for your Personal Data, we consider things such as the amount, nature, and sensitivity of the Personal Data, the purposes for which we process your Personal Data, the potential risk of harm or damage from unauthorised use or disclosure of your Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

8.3 In cases of aggregated data where we anonymise your Personal Data so that it can no longer be associated with you, we may use this information indefinitely without further notice to you.

8.4 If you wish to have certain data or information provided to us to be deleted, you may do so by sending a request to us on our contact email address provided at the bottom of this page. However, deletion of certain data or information may lead to restriction of your access to our certain Services.

8.5 You acknowledge and agree that certain data or information cannot be deleted due to our compliance with applicable laws, law enforcement requests or under any judicial proceedings.

9. Data Protection

9.1 Swabhiman understands the importance of protecting the integrity and confidentiality of your Personal Data and information. We take reasonable and appropriate physical, technical and administrative measures for the purpose of protecting your Personal Data from accidental loss, theft, misuse and unauthorized access, disclosure, modification and destruction, taking into account the risks involved due to the nature of the Personal data and in the processing of the Personal Data.

9.2 We limit access to your Personal Data to our employees, agents, contractors and other third parties on a need-to-know basis.

9.3 We have put in place procedures to deal with any suspected breach of Personal Data and shall notify you and/or any applicable regulatory authority of a breach where we are legally required to do so.

9.4 Despite striving to protect the information we maintain, we cannot ensure or warrant the security of any information that is transmitted to or held by us since data transmission and storage is neither error-free nor completely secure.

10. Data Storage

10.1 Your data will be stored on the servers of our hosting service.

10.2 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the Privacy Policy and other applicable laws.

11. Transfer of Data

11.1 The European Commission has determined that the transfer of personal information of its residents outside of Europe must be subject to a legal framework that adequately protects it. 

11.2 Some of our external third parties are based in and outside India. Consequently, the processing of your Personal Data may involve a transfer of data outside the country in which you are based.

11.3 You may contact us if you wish for further information on the specific mechanism used by us for transferring your Personal Data out of the country in which you are based.

12. Amendments to Privacy Policy

12.1 The Privacy Policy is regularly revised and modified from time to time to accommodate the changes in our Services and the applicable laws and make sure we continue to serve the privacy interests of our users to the best.

12.2 If our information practices change materially, we shall timely reflect the same in the Privacy Policy and modify the ‘last revised at’ column at the bottom of the page accordingly. 

12.3 We advise you to review the Privacy Policy periodically, and especially before you provide us with any information through the Services. In case of any major change that we believe should come to your notice, we shall notify you through email, subject to your consent to receive such updates. 

12.4 Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

12.5 If you are in Europe, you will not be required to agree to the changes made in this Privacy Policy, unless we specifically seek your consent.

13. Disclaimer

13.1 Swabhiman disclaims any liability, legal or otherwise, that may arise due to any act, omission or otherwise, caused on your part. 

13.2 You acknowledge that visiting this Website constitutes your implied acceptance of this disclaimer.

14. Contact Us

14.1 Individuals with inquiries or complaints regarding our Privacy Policy may contact us by using the “Contact Us” link provided on the Website or by sending an email to us on contact@swabhiman.org We try to timely attend to every message that we receive.

14.2 We also may archive your comments or queries and share them with our customer care team to improve our Services for you in the future.

14.3 You may also write to us at A/98, Budha Nagar, Bhubaneswar, Odisha, India-751006; or

Call us at  +91-8093246430

Last Revised on: 31st August 2020

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Swabhiman is a certified non-profit, civil society organization, registered under 12A, 80G of Income Tax Act. 1961. and FCRA Act.

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