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PRIVACY POLICY

INTRODUCTION

WELCOME TO THE PRIVACY POLICY OF RONALD MCDONALD HOUSE CHARITIES® OF CYPRUS

Ronald McDonald House Charities of Cyprus (“RMHC”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Collecting the personal data of patients and their families is imperative in order to provide the service and support we aim to provide. We also collect the personal data of our supporters so that we can process their donations and also, fundraise more efficiently for the purpose of ultimately, continuing to provide accommodation for families with children at specialist children’s hospitals.

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Ronald McDonald House Charities of Cyprus collects and processes your personal data. It is important that you read this privacy policy together with any other privacy policy, fair processing notice or information we provide on specific occasions when we are collecting or processing personal data about you so that, you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

CONTROLLER

Ronald McDonald House Charities of Cyprus is the controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

CONTACT DETAILS

Our full details are:
Full name of legal entity: Ronald McDonald House Charities of Cyprus
Email address: info@rmhc.org.cy, Telephone number: 00357 22 813444

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, the Cyprus supervisory authority for data protection issues (http://www.dataprotection.gov.cy/). We would, however, appreciate the chance to discuss your concerns with a view to accommodating the, before you approach the Commissioner so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 15 May 2020.
We collect your data through your interaction with us only if we have a legitimate reason to collect them. It is imperative that the personal data we hold about you is accurate and current. Therefore, please keep us informed if your personal data changes during your relationship with us. We really appreciate it if you let us know if your contact details change. We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal data we will make this clear on the RMHC Website.

THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Depending on the kind of relationship we have with you, we collect different data, depending on the purpose of the collection.

SUPPORTERS

If you support us (for example make a donation, volunteer, register to fundraise, bid on an auction prize or sign up for an event) we may collect, use, store or transfer different kind of personal data about you or your child (where you have provided your child’s data to us) which we have grouped together as follows:

  • Identity Data includes full name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments from you and other details of donations you have made.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    We also collect, use and share statistical or demographic data in an aggregated form for any purpose so that no individual can be identified from such data (Aggregated Data). For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

Where it is appropriate, we may also collect Special Categories of Personal Data about you: information relating to your health (for example if you are taking part in a high-risk event). We may also ask why you have decided to donate to us. We will never make this question mandatory, and only want to know the answer if you are comfortable telling us.

HOW IS YOUR PERSONAL DATA COLLECTED?

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

SUPPORTERS

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:

  • donate to us.
  • sign up for one of our events.
  • tell us your story.
  • purchase our products.
  • request marketing to be sent to you or
  • participate in a survey.

Please note that if you enter your details onto one of our online/offline forms, and you don’t “send” or “submit” the form, we may contact you to see if we can help with any problems you may be experiencing with the form or our websites.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect these personal data by using cookies, server logs and other similar technologies only if these are needed for the operation of the website. We may also receive Technical Data about you if you visit other websites employing our cookies, provided you consented to it. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

  • Technical Data from analytics providers such as Google based outside the EU;
  • Identity, Contact, Financial and Transaction Data collected when you register for one of our events, e.g. the data you enter into Eventbrite, any other event registration platforms;
  • Identity and Contact Data from online survey responses when you complete a survey on Survey Monkey or LimeSurvey.
  • Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp, Instagram or Twitter, you might give us permission to access information from those accounts or services.

SHARING YOUR STORY

You may choose to tell us about your experiences in the Ronald McDonald Family Room to help further our work. You may take on a role as an ambassador, attend our events, or sit on our House Boards. This may include sharing Identity, Contact or other Special Category Data such as biometric data, ethnicity or information relating to your health and family life. We will also monitor the types of people who are involved to ensure that the views we hear are representative of all people using our programs. If we have your explicit and informed consent (from our consent form), or your parent or guardian’s explicit and informed consent if you are under 16, this information may be made public by us at events and in materials and communications promoting our campaigning and fundraising work or in documents such as our annual report. Where your explicit and informed consent (from a joint RMHC and Family Restaurants Andreou and Co Ltd consent form) is given, we may share your information with McDonald’s Restaurants Ltd so they can promote RMHC on their own channels, such as the McDonald’s Cyprus website or their social media pages.

SUPPORT FOR FAMILIES

We provide accommodation and support to individuals and families with children receiving treatment in specialist children’s hospitals. Within that service we collect Identity, Contact Person and other Special Category personal data such as biometric data, ethnicity or information relating to the health and family life, in order to provide the accommodations services. This information is stored on our database, accessed only by trained individuals and retained only for as long is needed. RMHC will only share your details in exceptional circumstances and where is legally required, for example where a child reports abuse, or someone reports serious self-harm or a serious intention of harming someone else.

CHILDREN’S DATA

We only collect or publish a child’s personal data when we have the explicit informed consent of their parent or guardian. Usually, we collect the personal data of children when their family is using one of our programs. However, we may also collect data when children attend our events or fundraise for us. When we collect and manage information from children, we aim to manage it in a way which is appropriate to the age of the child.

Our events have specific rules about whether children can participate, and we will make sure advertising for those events is age-appropriate. Where we know or have reason to believe a child is under 14 our policy is not to collect personal information from them unless it is necessary for a specific activity and or where the child’s parent or guardian has first provided written consent to that specific activity. Where we know or have reason to believe a child is under 14, we will not collect (nor encourage any child to give) more detailed information than is needed by us to facilitate that child’s selected activities, without first obtaining the written consent of a parent or guardian.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. Where we need to PERFORM THE CONTRACT, we are about to enter into or have entered into with you, for example, receipt of a one-time donation, setting up an ongoing donation or when you purchase our products.
  2. Where it is necessary for our LEGITIMATE INTERESTS (or those of a third party) but your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our charity in pursuing our mission: to ensure we have sufficient funds and expertise to develop and sustain free accommodation at specialist children’s hospitals in the Cyprus. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us on info@rmhc.org.cy or 0035722813444
  3. Where it is necessary for us to comply with LEGAL AND REGULATORY REQUIREMENTS.

Generally, other than as set out above in relation to experiences and children, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via telephone, post, email or other electronic means. You have the right to withdraw consent to marketing at any time by contacting us on info@rmhc.org.cy or 0035722813444.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

MAKING YOUR STAY AT THE HOUSE BETTER

The RMHC House’s purpose is to provide free accommodation to the parents and siblings of a child who is undergoing hospital treatment. During the family’s stay at the RMHC House in Cyprus, the family will be asked to provide personal information, such as: date of birth, name, surname, home address, email address and phone number of all the family members who will seek accommodation at the RMHC House. In addition, the family may be requested to provide the child’s (undergoing treatment) date of birth, name, surname, as well as the department where it is being hospitalized. This information is being recorded to facilitate the family’s stay us. It will not be utilized for anything further than the purpose at hand and it will be destroyed 12 months following the family’s departure from the House. 

BUILDING PROFILES OF SUPPORTERS AND TARGETING COMMUNICATIONS

We may use profiling techniques to ensure communications are relevant and timely, and to provide an improved experience for our supporters.  Profiling also allows us to target our resources effectively, which donors consistently tell us is a key priority for them.  We do this because it allows us to understand the background of the people who support us and helps us to make appropriate requests to supporters who may be able and willing to give more than they already do.  Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would. When building a profile, we may analyze geographic, demographic and other information relating to you in order to better understand your interests and preferences in order to contact you with the most relevant communications.  In doing this, we may use additional information from third party sources when it is available. We will ask for your consent prior to engaging into any profiling technique.

UPDATES & COMMUNICATION FROM US

We strive to provide you with choices regarding certain personal data uses, particularly around marketing communications. With your consent, we will contact you to let you know about the progress we are making and to ask for donations or other support.  Occasionally, we may include information from partner organizations or organizations who support us in these communications.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what may be of interest to you. This is how we decide which events and services may be relevant to you. You will receive communications from us if you have requested information from us, donated to us, or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving communications.

THIRD-PARTY MARKETING

We will share Identity, Contact and Technical Data with third parties including Facebook, provided that you have consented to this through your advertising preferences.  For more details about advertising preference please see our cookie policy.

We use your information to improve your experience, this data sharing enables us to create custom audiences. Some of those third-party recipients may be based outside the European Economic Area- for further information including on how we safeguard your personal data when this occurs, see ‘International transfers’. If you don’t want to see our targeted advertising, you can set ad preferences in your Facebook settings or you can adjust your advertising preferences in your browser settings. 

We will share personal information with law enforcement or other authorities if required by applicable law. If we run an event in partnership with another named organization your details may need to be shared. We will clearly set out what will happen to your data when you register for a specific event. We will never sell your personal data.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us. Same applies for any process which is executed because you gave us your consent. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, event registration, donation agreement or other transactions. To exercise your right to opt out please contact us on info@rmhc.org.cy or 0035722813444.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third Parties such as:

Event organizing companies or volunteer groups based in Cyprus, which help us deliver fundraising events like Gala Dinners and Sports happenings. We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: where we use certain service providers, we may use contracts which give personal data the same protection it has in Europe; and where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties who strictly need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

In addition, our online forms are always encrypted, and our network is protected and routinely monitored. Where we use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they have collected or have access to. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We ensure that there are appropriate technical controls in place to protect your personal data.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHT

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 
  • You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
    If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

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.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a 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.

We may offer links to sites that are not operated by RMHC. If you visit one of these linked sites, you should review their privacy and other policies. We are not responsible for the policies and practices of other companies.