AFSA (Animal-Free Safety Assessment) Collaboration Privacy Policy

Privacy Policy - AFSA

Last updated 9 March 2020

This notice tells you what to expect when we collect your personal information.

1. Who we are and what this policy is about

The AFSA Collaboration brings together corporate and non-profit leaders who share the goal of accelerating a modern, species-relevant approach to safety assessment globally to better protect people and our planet, and hasten the replacement of animal testing.  The AFSA Collaboration website is operated by Humane Society International (HSI).  Humane Society International, a charitable non-profit organization headquartered at 1255 23rd Street, NW, Suite 450, Washington, DC, USA, is one of the largest animal protection organizations in the world with affiliated organizations in several countries that share a common mission to promote the humane treatment of animals worldwide and to foster respect, understanding and compassion for all creatures through public education, awareness and direct animal care programs.    

This privacy policy governs the URL www.afsacollaboration.org (the “website”) and certain communications sent out by the AFSA Collaboration.   

We respect your right to privacy and are committed to keeping your personal information private and secure through our compliance with this Privacy Policy. You can visit the website without telling us who you are or revealing any identifying information about yourself. However, because the website includes areas in which visitors can provide personally identifying information and because we monitor website usage, we have developed this privacy policy to inform you of our policies and practices regarding information we collect about you.

This notice contains information about:

  • Why we collect personal information about you
  • What personal information we collect from you and how we collect the information
  • How we use your personal information
  • How long we keep your personal information
  • Information sharing and third parties and where we store your personal information
  • How we keep your personal information secure
  • Your rights if you are a resident of the EEA or UK
  • How you can complain or contact us

Please read this privacy policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this privacy policy in general or any part of it, you should not access the website

Changes to the Privacy Policy

We keep this policy under regular reviewHSI reserves the right to modify or amend this privacy policy at any time and for any reason.  Please check back frequently to see any updates or changes to this policy.


2. Why we collect personal information about you

We hold and process visitors’ personal data for a variety of reasons:

  • To respond to enquiries from visitors who complete the contact form;
  • To manage registrations for AFSA Collaboration events; and
  • To comply with legal obligations.

3. Information we collect about you and how we collect the information

The information we collect on or through the website may include: (1) information that you provide to us by filling in forms on the website (this includes information provided at the time of registering interest to join the AFSA Collaboration, registering for an AFSA Collaboration event or use of the contact form), as well as records and copies of your correspondence (including email addresses) if you contact us; and (2) information we collect through automatic data collection technologies.

Information you voluntarily provide

We collect and maintain certain personal information about you when you send us an e-mail or complete any of our forms, such as when you request information from us. Such information may include your name and e-mail address, and other information collected in the forms. 

Other information

We also collect certain usage information to better understand how visitors use the website, which includes your IP address, URL you are coming from before visiting the website. The website logs these IP addresses, URL’s, device information such as identifier, name and type of operating system, mobile network information and web information such as browser type and pages accessed on the website, and aggregates them for system administration and to monitor the use of our site. We use the aggregated information to measure the number of visits to our site, the average time spent on our site, the number of pages viewed, and various other site statistics. This monitoring helps us to provide a more useful and engaging online experience to website visitors, and helps us to improve the quality of our content.

The website uses cookies to make the results available for any searches you perform using the website search functionality. A cookie is a small file that is sent out by a web site, accepted by the user’s browser, and placed on the user’s hard drive. We do not match any information gathered by cookies with personal information you may have voluntarily submitted. If you do not accept the use of these cookies, please disable them by changing your browser settings so that cookies from the website cannot be placed on your computer. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/.

The website uses cookies or similar technologies for remarketing purposes with Google Analytics to display content-specific advertisements to visitors who have previously visited our site when those visitors go to other websites that have the Google Display Network implemented. We also use Google Analytics Demographics and Interest Reporting. The reports disclose website trends without identifying individual visitors.  You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

Third-party vendors, including Google, use first-party and third-party cookies together for re-targetting, where you may see an ad based on past visits to the website displayed on other sites you visit.You may opt out of Google’s use of cookies by visiting Google’s Ads Settings at any time. Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.


4. Ways information about you is used

We may use the information collected for various purposes:

  • to contact you regarding AFSA Collaboration events we feel you may be interested in;
  • to allow you to participate in interactive features of the Website when you choose to do so;
  • to provide and maintain the Website;
  • to gather analysis to improve the Website;
  • to monitor usage of the Website; and
  • to detect, prevent and address technical issues.

Every recipient of our electronic communications can quickly and easily “opt out” of future such communications by contacting us at infosec@humanesociety.org or by following the instructions on any electronic communication we send.


5. How long do we keep your personal data?

We will retain your personal data for as long as is necessary for the purposes set out in this privacy policy.

We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.


6. How do we share your personal data?

We do not sell, rent or lease your personal information to others except as described in this privacy policy. We share your information with selected companies and individuals as service providers to facilitate the website. These categories of recipients include:

  • to advertisers and advertising networks, including Google, that require the data to select and serve relevant adverts to you and others; and
  • third-party service providers who have provided us with assurances that they process personal information under suitable data protection arrangements and security controls in place. These third-party service providers include: cloud storage providers, IT services providers and analytics service providers

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

  • comply with a legal obligation, process or request;
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Where do we store your personal data?

Your information, including personal data, may be transferred to – and maintained on – computers and servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including personal data, to United States and process it there.

By submitting your personal data, you agree to this transfer, storing or processing outside of your jurisdiction in accordance with this privacy policy.

Other
From time to time, the website may link to other web sites not operated by HSI. HSI attempts to link only to those web sites which also respect a visitor’s privacy and the goals of the AFSA Collaboration. However, if you click on a third-party link, you will be directed to that third party’s site.  HSI has no control over and assumes no responsibility for the content or privacy policies or practices of third-party web sites. We strongly advise you to review the privacy policies of every site you visit.  If you find inoperable links or are concerned about any of the sites that the Website currently links to, please inform the AFSA Collaboration by contacting us at infosec@humanesociety.org.


7. How we keep your personal information secure?

Security

The security of your data is important to us; however, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal data against loss, theft and unauthorized use, access or modification.

HSI uses generally accepted, industry-standard security systems, software, and encryption technologies — Secure Sockets Layer (SSL) — for the secure transfer of personal data and to protect against unauthorized access to HSI servers, equipment, and other components of our online presence. Our web servers are hosted off-site at multiple, physically secure facilities with limited access.

8. Children’s Privacy

The website is not intended for use by anyone under the age of 18 (“Child”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


9. Residents of the European Economic Area (EEA) and the United Kingdom (UK)

If you are a resident of the EEA or the UK, this section 9 of the privacy policy tells you what to expect when we collect personal information from you.  This section is supplemental to the information provided in the previous sections of this policy, which previous sections also apply to you. 

Data Controller

HSI is the “data controller” of the personal data processed in connection with the website for the purposes of the General Data Protection Regulation (the GDPR) (which applies across the EEA and the UK).  Personal data is defined in the GDPR as any information relating to an identified or identifiable natural living person.

Legal Basis for Processing

The laws on data protection provide a number of different reasons (legal basis) for organizations to collect and process your personal data.  We generally process data on the basis that it is necessary for the pursuit of our legitimate interests.  We process data to pursue our legitimate interests in ways which might reasonably be expected and which do not materially impact your rights, freedom or interests. For example, by sending direct marketing information to keep our supporters updated on projects, activities, news, events and action alerts. We will only do this where we have reason to believe that this information will be of interest to you. 

In circumstances where required by applicable law, we will rely on consent as a basis for processing personal data and we will specifically obtain your consent in the course of collecting the data.  We may also need to collect and process your data if we are required to by law.  We may also use data to improve our level of service. Where we do this, we do it to help inform us how to improve the way we work since both we and those we deal with have an interest in us doing so.

Every recipient of our electronic communications can quickly and easily “opt out” of future such communications by following the instructions on any electronic communication we send.

Withdrawal of Consent

Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by e-mailing us at infosec@humanesociety.org. You may also unsubscribe at any time in every issue of our newsletters.

Additional Rights

If you are in the European Union, depending on the information we hold about you and the reason for us holding it, you have certain rights which are set out below.  You may have additional rights in relation to the personal data we hold about you. We set out below an outline of those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by sending us a copy of your passport or driving license. To exercise any of your rights, please email dpo@humanesociety.org.  Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

  • Access: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
  • Portability: You have the right to receive a subset of the personal data you provide us if we process it on the bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal data to another party.
  • Correction: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed.
  • Erasure: You may request that we erase the personal data we hold about you in the following circumstances: where you believe it is no longer necessary for us to hold the personal data, we are processing it on the basis of your consent and you wish to withdraw your consent, we are processing your data on the basis of our legitimate interest and you object to such processing, you no longer wish us to use your data to send you marketing or you believe we are unlawfully processing your data.  
  • Restriction of Processing to Storage Only: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in the following circumstances: you believe the personal data is not accurate for the period it takes for us to verify whether the data is accurate, we wish to erase the personal data as the processing we are doing is unlawful but you want us to simply restrict the use of that data; we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defence of legal claims; and you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
  • Objection: You have the right to object to our processing of data about you and we will consider your request.

10. How you can complain or contact us

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us at infosec@humanesociety.org and we will endeavor to deal with your request.

Contacting HSI

If you would like to contact HSI about correcting information we might have collected, or if you have any questions about this privacy policy, please e-mail us at infosec@humanesociety.org, or write to us at Office of the General Counsel, HSI, 1255 23rd Street, NW, Suite 450, Washington, DC 20037 USA.

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