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Online Privacy Policy

Last Revised: March 2024

This Online Privacy Policy (“Policy”) applies to information that Global Action to End Smoking (“we”, “us”, “our”) may obtain about you when you visit globalactiontoendsmoking.org (the “Site”) or when you otherwise interact with us. This Policy provides information about how we may collect information about you through the Site, how we may use and share such information, how we safeguard the information we collect, and how you may contact us regarding our privacy practices. Please read this Policy carefully before using the Site or submitting information to us. By accessing or visiting this Site, you indicate your understanding that the collection, use, and sharing of your information is subject to the terms of this Policy. If you do not consent to the collection, use, and sharing of your information as described in this Policy, please do not provide us with such information.

This Policy also applies to our grantees and those who submit grant applications to us. If you are a grantee or plan to submit a grant application to us, please read the grantee specific section below.

If you are located in the European Economic Area or the United Kingdom, please have pay particular attention to the corresponding section indicated below.

Information We Collect From You

We may collect and process the following information about you:

  • Contact Data. You may provide us with your contact details, such as name, email address, country, or other similar information, which we may use to respond to your inquiries, to send you informational emails and updates, or for administrative purposes.
  • Log Data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Site and record that data in log files. This log data may include your Internet Protocol (IP) address, the address of the web page visited before using the Site, browser type and settings, the date and time the Site was used, information about browser configuration and plugins, language preferences, and cookie data.
  • Device Information. We may obtain information about devices that access the Site, including the type of device, its operating system, device settings, unique device identifiers, and crash data.
  • Online Portal. If you register for an account on our online portal or submit a proposal through our online portal, we or our vendor may collect your name, email address, or other similar information.
  • Economic and Financial Information. If you choose to make a donation to us via our website, we or our vendor may collect your bank account details and credit/debit card details.
  • Other Information You Provide. This category includes emails and other communications that you send us or otherwise contribute, such as support inquiries or when you comment publicly on the Site. Please be aware that information you post on public parts of our Site may be visible to anyone.
 

How We May Use the Information We Obtain

We may use information about you for purposes described in this Policy or otherwise disclosed to you on the Site or at the time of collection. For example, we may use information about you to:

  • Respond to emails, inquiries, comments, questions, or other requests for support;
  • Process your proposals and Expressions of Interest;
  • Manage your access to the online portal;
  • Send you informational notices about news and events;
  • Ensure the security and integrity of our Site;
  • Monitor and analyze trends, usage, and activities of visitors and users on the Site;
  • Facilitate, manage, personalize, and improve your online experience;
  • Comply with applicable laws, regulations, or legal process as well our company policies;
  • Allow you to participate in the features we offer on the Site;
  • Contact you regarding your use of the Site or, in some cases, changes to our policies;
  • Process any donation(s) we may receive from you;
  • Prevent, investigate, identify, or take any other action with regard to any suspected or actual fraudulent or illegal activity or any activity that violates our policies; or
  • For any other purpose, with your consent.
 

We also may use the information we obtain about you in other ways, in which case we will notify you at the time of collection.

Information We Share With Third Parties

  • With our affiliates or business partners when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the Site.
  • With our service providers that perform services on our behalf. For example, we may use third parties to help us send email communications or to assist with data storage.
  • In order to follow the law or protect rights and interests. For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests (such as enforcing our Terms of Use), or prevent fraud or abuse. In particular, we may disclose your personal data in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
  • During negotiations of any proposed or actual transaction, such as a partnership or joint venture, or any other type of legal event.
 

Cookies and Data Analytics

In addition to information you submit through the Site, we may collect certain information using automated tools such as cookies and Google Analytics.

“Cookies” are small text files that are stored by your browser or other application on your computer’s browser or hard drive and that a website can use to recognize repeat users, facilitate ongoing access to and use of the website, and allow a website to track usage and collect aggregate data in order to improve the website. This Site may set cookies to automatically track data and non-personal information about users.

Most web browsers accept cookies by default, but you may be able to adjust your browser settings to remove or reject cookies. Please note that blocking cookies may affect the availability and functionality of our Site and other websites. Also, disabling cookies may invalidate opt outs that use cookies to recognize devices that have opted out.

We may use IP addresses to analyze trends, administer the web site, track volume of usage, and gather broad demographic information for aggregate use. IP addresses are not linked to any user’s personal information. We use this information to measure the number of visitors to the different sections of this web site and to help make the web site more useful.

We use the following types of Cookies:

  • Necessary Cookies: These our vital for our website’s functionality.
  • Analytics Cookies: These help us improve by analyzing site usage and user demographics. While these cookies provide insights into how users found our site, their previous visits, viewed pages, engagement duration, and patterns, they do not disclose any personal information.
  • Campaign/Social Media Cookies: (If applicable) These track the effectiveness of our outreach and promotional activities.
 

Necessary cookies are essential to provide you with the services you request on the Site and for us to comply with legal obligations such as our security obligations under data protection law. We do not need to ask for your consent to use these cookies as without them we would not be able to provide the services requested by you. These are always active on the Site.

Analytics Cookies and Campaign/Social Media Cookies are only active on our Site if you consent to it via our Cookie consent mechanism.

The following information may be collected about you via the Cookies on our site:

  • Your IP address, MAC address, browser type, operating system, device-identifying information, type of computer, and type of Web browser software, the specific webpages visited during your connection, and the domain name from which you accessed the Site.
  • Information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data.
  • We may use “cookies” of different types to recognize your computer, as described in greater detail below. A cookie is a small text file that a website, online application, or e-mail may save to your internet browser and/or your computer’s hard drive for use in subsequent visits to the Site or other sites.

Information about your use of this Site and others may be collected across time, devices, and websites, and used for various purposes, including to associate different devices you use and to deliver relevant and/or retargeted content, including interest-based ads. We also may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from third parties, such as our service providers.

The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities. The Site does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.

We may use certain third-party web analytics services, such as Google Analytics, to help us understand and analyze how visitors use the Site. Information generated by these services (e.g., your IP address and other information related to use of the Site) may be transmitted to and stored by these service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Site, compiling statistical reports on the Site’s activity, and providing services relating to Site activity and other Internet usage. We use Google Analytics to monitor activity on the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps,” located at www.google.com/policies/privacy/partners.

Links to Other Websites

Our Site contains links to other sites. There is a possibility that those sites may use cookies to collect a visitor’s personal information. We cannot control the use of cookies by sites linked to our site and we are not responsible for the privacy practices or content of other sites.

Social Media

This Site also may include features that are designed to permit interactions with third-party websites or services, including third-party social networks. For example, you may be able to “like” or “share” content from this Site on other websites or services.

We are not responsible for, and make no representations regarding, the policies or business practices of any third parties, including analytics service providers and third-party services associated with the Site, and encourage you to familiarize yourself with their privacy policies and terms of use.

Data Security

We take reasonable measures designed to help protect personal information we obtain through the Site from loss, theft, misuse, or other unauthorized activity. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we do not guarantee the security of your information collected through the Site.

Grantees

This Policy also concerns our processing of personal data of grantees who have been awarded grant funding by us and applicants for grant funding (“Grantee”). If you are a Grantee, please ensure you read this Policy in its entirety for full information about how we process your personal data, while also paying particular attention to the following:

  • We collect information about you from the information you provide to us when you interact with us before making an application for grant funding, when you submit a formal application for an award and in other ways as you interact with us during your time as a Grantee.
  • We collect Contact Data, Log Data, Device Information and Online Portal (as defined above) related personal data about you and any other information relevant to grant funding application or award.
  • The basis on which we process Grantee personal data is our legitimate interests in executing our charitable mission of ending smoking by funding grants in furtherance of the purposes for which we were created and in monitoring and evaluating the performance of our grants. We may also process your personal data for our compliance with our legal obligations.
  • Personal data of unsuccessful applicants is maintained for no more than five years after the application process, except for any records we are required to retain for a longer period. Personal data of successful applicants will be kept indefinitely subject to applicable laws. If you are a Grantee based in the European Economic Area or the United Kingdom, please review the retention period information set out in that section.
 

Visitors From Outside the United States

Please be aware that information collected through the Site may be transferred to, processed, or stored in various countries, including the United States. Data protection laws in these countries may be different from the laws in your country of residence.

For Users in the European Economic Area or the United Kingdom

We are committed to fulfilling our responsibilities under the European Union’s General Data Protection Regulation (“EU GDPR”) and the EU Law retained version of the EU GDPR (“UK GDPR”) in relation to the collection, retention, use, and other processing of personal data that is obtained when EU and UK data subjects visit and interact with the Site. This section of this Policy sets forth how we process EU and UK personal data in our role as a data controller (i.e., when we are responsible for determining the purpose and means of the processing). We are the data controller of personal data you disclose to us in connection with your use of the Site.

Personal Data We Collect

The types of personal data we collect are set out above. We do not collect any special categories of personal data about you (this includes details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How and Why We Use Your Personal Data

We use the personal data we obtain for the purposes set out elsewhere in this Policy. We will only use your personal data for the purposes for which we collected it as explained above, or as otherwise set out in this Policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We process your personal data pursuant to the following legal bases:

  • We have a legal obligation to process your personal data, such as to comply with applicable tax or other government regulations or to comply with a court order or binding law enforcement request.
  • We have a legitimate interest in using your personal data. In particular, we have a legitimate interest in the following cases:
    • The processing is necessary for us to provide you with the services you request, or to respond to your inquiries.
    • To analyze and improve the safety and security of our Site. This includes implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
    • To maintain and improve the Site.
    • To operate the Site and provide you with certain tailored communications to develop and promote our mission and the operation of our organization.
  • If you have consented to the use of your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. When we use your consent as the legal basis for the processing, you can change your mind at any time by contacting us using the details below. If you withdraw consent, this will not affect the lawfulness of the processing carried out prior to your withdrawal.
 

Note that our Site is dynamic. We may introduce new features, which may involve new or different personal data processing activities. If we intend to process your personal data for a purpose not described above, we will notify you and request your consent to the change as appropriate. We will also modify this Policy.

Where we need to collect personal data by law, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with a grant).

How We Protect Your Personal Data

We maintain appropriate technical and organizational safeguards designed to help protect personal data from unauthorized disclosure or access and accidental or unlawful destruction, loss, or alteration. Although we use reasonable efforts to safeguard personal data, we cannot guarantee the security of your information obtained through the Site.

How Long We Retain Your Personal Data

We will store your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal data from our systems and records.

How We Transfer Your Personal Data

If we transfer your personal data out of the United Kingdom or the European Economic Area (“EEA”) to countries not deemed by the UK’s Information Commissioner’s Office (“ICO”) or The European Commission to provide an adequate level of personal data protection, the transfer will be based on Standard Contractual Clauses approved by the ICO and/or The European Commission as applicable, which impose data protection obligations on the parties to the transfer, unless an exemption under the UK/EU GDPR applies. Please contact us if you want further information on the specific mechanism we have used to transfer your personal data.

Your Rights and Choices

The UK/EU GDPR provides UK and EU data subjects with certain rights regarding their personal data. Subject to certain conditions, you may ask us to take the following actions in relation to your personal data that we hold:

  • Provide you with information about our processing of your personal data and give you access to your personal data.
  • Update or correct inaccuracies in your personal data.
  • Delete your personal data.
  • Restrict the processing of your personal data.
  • Object to our processing of your personal data for direct marketing purposes.
  • Object to reliance on our legitimate interests as the basis for processing of your personal data.
  • Transfer a machine-readable copy of your personal data to you or a third party of your choice.
 

You can submit these requests to us by email or our postal address provided below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than one calendar month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us using the details below or lodge a complaint with a supervisory authority. However, we would encourage you to contact us in the first instance as we aim to resolve any concerns or complaints promptly, efficiently, and satisfactorily you may have in relation to our processing of your personal data.

Your Choices

You may unsubscribe from receiving promotional emails from us by following the instructions provided in those email communications. Please note that even if you opt out of receiving promotional communications from us, we may continue to send you non-promotional emails, such as communications regarding our ongoing relationship with you. Please allow up to ten days for us to process your unsubscribe request.

Changes to This Online Privacy Policy

We reserve the right to change this Policy from time to time. We encourage you to check this page whenever you use the Site, to stay informed about our data practices. We will update the last revised date listed at the top of this page when we make material changes to this Policy.

Contact Us

If you have questions about this Privacy Policy, you may contact us via email at legalnotice@actiontoendsmoking.org or by writing to us at:

Global Action to End Smoking
Attention: PRIVACY INQUIRY
420 Lexington Avenue, Suite 300
New York, New York 10170

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