This Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us. We may from time to time update this Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.
By using our platform, it is acknowledged that you have read and accept the terms of this Policy.
1. YOUR PERSONAL DATA
- 1.1 “Personal Data” refers to any data or information (whether true or not) about you from which you can be identified, either (i) from that data; or (ii) from that data and other information to which we have or are likely to have access. 2. COLLECTION OF PERSONAL DATA
2. COLLECTION OF PERSONAL DATA
- 2.1 Force for Good may collect your Personal Data in one or more of the following ways when you:
- (a) visit our websites or use our mobile applications;
- (b) donate through our websites or mobile applications;
- (c) attend our events, conferences, forums, workshops or talks (which may include us taking photos and/or video recordings for publicity purposes);
- (d) register with us as volunteers;
- (e) interact with any of our employees, interns, volunteers, board and committee members e.g. via meetings, emails or telephone calls;
- (f) respond to our request for additional Personal Data;
- (g) request that we contact you, be included in an email or other mailing list;
- (h) respond to our initiatives or programs;
- (i) submit your Personal Data to us for any other reasons;
- (j) apply to work with Force for Good;
- (k) you choose to connect with third party social networking services who (subject to applicable law and their privacy policies) may provide your Personal Data to us.
- 2.3 If you are under the age of 16, you shall consult your parent or guardian before providing us with your Personal Data.
- 2.4 Force for Good will take such reasonable steps as are practical to ensure that the Personal Data we collect is accurate and complete. Please help Force for Good by ensuring that all Personal Data that you submit is complete and accurate. You may update us when there are any changes to the Personal Data which you have provided to us by emailing us using the contact details below or, if applicable, amending your account information. Where we receive such a request from you, we will correct or complete your Personal Data as soon as reasonably practicable.
- 2.5 Force for Good will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating us of any changes in your Personal Data that you had initially provided us with. Failure to provide complete, accurate, true and correct information may result in our inability to provide you with services and/or to deal with a request you have made.
3. PURPOSES FOR THE COLLECTION, USE & DISCLOSURE OF YOUR PERSONAL DATA
- 3.1 Force for Good may collect, use and/or disclose your Personal Data for the purposes for which we have (i) specifically obtained your consent or (ii) other purposes as described in this Policy where we have a legitimate interest or another lawful basis for processing such Personal Data as identified in this section 3. The key purposes are listed below but there may be other purposes we make you aware of from time to time:
- (a) Marketing and Advocacy
- (i) to contact you to inform you about Force for Good’s and/or Force for Good-related organisations’ products and services, or other information which may be of interest to you. We may also invite you to participate in Force for Good events and activities. So far as applicable data protection law requires, we will only send direct marketing by email or electronic means where we have your consent to do so.
- (b) Administration and Servicing
- (i) to provide our services to you in accordance with our terms and to carry out your instructions or respond to your queries;
- (ii) assess and process your requests to Force for Good;
- (iii) administer your third-party interactions through Force for Good (e.g. when you donate to other charities or volunteer with other organisations);
- (iv) compiling statistics for Force for Good and/or industry exercises and studies, to design and improve our products and services for you;
- (v) compliance monitoring and audit reviews;
- (vi) complying with guidelines and policies as set out in our terms or elsewhere on our website or mobile applications;
- (vii) providing general information on product enhancements, services and policies which are relevant to your needs;
- (viii) investigating any allegation or suspicion of fraud, misconduct, security breach and any suspected or alleged unlawful action or omission;
- (ix) archiving, backing-up or destroying your Personal Data;
- (x) informing you of changes and updates to our services, policies, terms and conditions and other administrative information;
- (xi) managing and administering our website, mobile applications, our systems and operations;
- (xii) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities and agencies; and/or
- (xiii) enabling us to investigate and deal with complaints or legal claims and/or allowing us to establish, exercise or defend our legal rights.
- (a) Marketing and Advocacy
- 3.2 Where Personal Data is submitted by you on behalf of another individual or concerns another individual other than yourself (or, in the case of situations where you, as a representative of your company or organisation are submitting the personal data of individuals as part of the disclosures by the company or organisation to us), you represent and warrant to us that, so far as legally required, any necessary consents (procured in accordance with applicable data protection legislation, including without limitation the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”), the UK and EU General Data Protection Regulation (together “GDPR”) and California Consumer Privacy Act (“CCPA”) for such purposes stated in the relevant sections of this Policy) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request. Where such consent is not legally required, you represent and warrant that you have a lawful basis for sharing such other person’s Personal Data with us and have done so in compliance with applicable law.
- 3.3. Please note that the particular Personal Data that we collect, the purposes it is used for and who it may be shared with may occasionally vary, depending on the territory or country in which you are located. For instance, if you are based in the United Kingdom and want to make your donation subject to UK Gift Aid, we will ask for additional information including your email, home address and (optional) phone number which then may be sent through a third party before being received by the respective charity (e.g. if you make a donation through the Percent payment platform – see our User Terms and Conditions for more details).
4. DISCLOSURE OF PERSONAL DATA
Personal Data will be protected and kept confidential but, subject to the provisions of any applicable law, including without limitation the PDPA, GDPR and CCPA may be disclosed for the purposes listed above, where applicable, to Force for Good personnel, our affiliates and other service providers in connection with the purposes described above, including, without limitation:
- (a) Our employees, volunteers, board and committee members;
- (b) Force for Good-related organisations as may be notified to you from time to time;
- (c) Banks, government agencies or their agent banks, credit card companies and other financial institutions for the processing of any monies receivable or payable;
- (d) Third party service providers, including those providing the following services courier services, payroll, mailing, information technology, data processing and storage, and insurance;
- (e) Any liquidator, receiver, official assignee/trustee, judicial manager or any other person appointed under or pursuant to any applicable law or court order in connection with the bankruptcy, liquidation, winding up, judicial management or any other analogous process in respect of any individual, company or business
- (f) Our professional advisers such as auditors and lawyers;
- (g) Any judicial, administrative or regulatory body, any government or public or government agency, or any parties thereof having jurisdiction over Force for Good;
- (h) Any other party to whom you authorise us to disclose your Personal Data.
5. OVERSEAS TRANSFERS OF PERSONAL DATA
Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. Where Personal Data is to be transferred out of the United Kingdom or European Economic Area (EEA), we will comply with relevant provisions of the GDPR governing the transfer of such Personal Data to third countries. This includes, where legally required, obtaining consent from you to transfer your Personal Data to such territory, and before you give consent, providing you with a reasonable written summary on the extent of the protection offered to the Personal Data to be transferred overseas, and/or, where legally required, taking appropriate steps to ascertain that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that meets the standards required under the PDPA or GDPR (as applicable).
6. WITHDRAWAL OF CONSENT
- 6.1 If you wish to withdraw your consent or object to any use or disclosure of your Personal Data as set out in this Policy or in accordance with your rights under applicable law (for example, your right to object to receiving direct marketing from us), you may contact Force for Good’s Data Protection Officer (DPO). The DPO’s contact information is located in Section 12 (Contact Us).
- 6.2 Please note that if you withdraw your consent or object to the collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, we may not be able to continue providing our services or performing our contractual obligations to you. Such withdrawal may also result in the termination of any agreements or arrangements you may have with us. Force for Good’s legal rights and remedies are expressly reserved in such event. For example, in some cases, we may have a compelling legitimate interest or legal requirement to continue to hold or process your Personal Data for certain purposes (e.g. for tax reporting or to deal with potential legal claims).
- 6.3 Subject to the above, Force for Good will strive to effect your withdrawal of consent or objection within 21 working days (or one month, if earlier) of your contacting us in this regard and will notify you if more time is required or if we need more information to implement your request. Please note that the forgoing does not affect the processing of your Personal Data carried out before such request takes effect.
7. YOUR DATA RIGHTS
- 7.1 Under GDPR and relevant data protection law, you have certain rights in relation to the Personal Data that we hold and process about you. You may request access to or make corrections to your Personal Data records that Force for Good stores or processes. Under the GDPR, you may also request that we restrict certain processing of your Personal Data (for example where you dispute its accuracy). In some cases, where Force For Good is processing your Personal Data to perform its services or our processing is based on your consent, the GDPR gives you the right to request that we transfer a copy of your Personal Data in electronic format to another service provider.
- 7.2 Please submit your request to Force for Good’s DPO identifying yourself and indicating the Personal Data that the request concerns. For the DPO’s details, refer to 12 (Contact Us).
- 7.3 Force for Good will strive to respond to each request for access or correction as soon as reasonably possible or as soon as practicable, and as accurately and completely as necessary. However, please note that we may refuse your request under certain circumstances as laid out under the PDPA or GDPR, where relevant. Where legally permitted, we may also charge you a reasonable administrative fee for the handling and processing of your request to access your Personal Data (if so, we will provide you with a written estimate of the fee we will be charging).
- 7.4 Our response time to your request will be in accordance with the timescales set out under PDPA, GDPR or other applicable laws to which we are subject. Please note that we may require further information to verify your identity or clarify your request before we can deal with it.
- 7.5 Where you feel that we have not complied with relevant data protection law when processing your Personal Data, under the GDPR and certain other data protection laws you have a right to complain to a relevant data protection regulatory authority (for example, in the UK this is the Information Commissioner’s Office or ICO – see www.ico.org.uk).
8. PROTECTION, POLICIES AND PROCEDURES
- 8.1 We will endeavour to protect your Personal Data in our possession and will guard against risks of unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures.
- 8.2 We will endeavour to ensure that our systems are secure and that they meet the industry standards.
- 8.3 To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect.
- 8.4 Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the internet is completely secure and by providing your Personal Data over the internet, you are transmitting information at your own risk.
9. RETENTION OF YOUR PERSONAL DATASURE OF PERSONAL DATA
We will retain your Personal Data for as long as you use our services and it is necessary, required or relevant for business or legal purposes. The legal criteria we adopt for the retention of Personal Data are based on applicable law and guidelines issued by relevant data protection regulatory authorities and the purposes for which such data is used.
- 10.1 When you access our website or use our mobile applications, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites/applications and common entry and exit points into our websites/applications.
10.2 We use “cookies” where a small data file is sent to the browser on your computer or mobile device to store and track Aggregate Information about you when you enter our website or use our mobile application. The types of cookies we currently use are as follows:
Essential or Necessary Cookies: These cookies enable core functionality such as security, verification of identity and network management of our websites or mobile applications. These cookies cannot be disabled.
Marketing Cookies: These cookies are used to track advertising effectiveness to provide a more relevant service and deliver more relevant marketing information to suit your interests.
Functional Cookies: These cookies collect data to remember choices users make when they visit our website or mobile application to improve and give a more personalised experience. For example, if a user has previously indicated cookie preferences, made a language selection or entered their details, these can be remembered the next time that user returns using the same device.
Analytics Cookies: These cookies help us to understand how visitors interact with our website or mobile applications, discover errors and provide overall analytics of how our services are accessed and used. This helps us improve our websites, mobile applications and services.
- 10.3 Should you wish to disable the cookies or tracking technologies used on our website or mobile applications, you may do so by changing the settings on your web browser (such as Google Chrome, Microsoft Edge or Apple Safari). However, where you disable certain cookies, you may not be able to access or receive full functionality from certain part(s) of our websites, mobile applications or services.
11. THIRD-PARTY SITES
12. CONTACT US
Should you have any questions, feedback or complaints relating to the use or disclosure of your Personal Data; wish to exercise your rights as described in this Policy; or, if you wish to know more about our data protection policies and practices, please contact our Data Protection Officer at email@example.com
- 13.1 As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time.
- 13.2 We reserve the right to amend the terms of this Policy at our absolute discretion. Any amended Policy will be posted here as soon as reasonably practicable and you should check this Policy on our website from time to time if you want to make sure that you have seen the latest version.