Big Life Foundation respects your privacy. We collect information to provide services to you, update you on the impact of your contributions, and communicate updates on our work on the ground in East Africa. Big Life recognizes that we must maintain and use your information responsibly.
This policy describes what personal data we collect, how we use it, and your choices. It applies to information collected by Big Life Foundation USA, Big Life Foundation Canada, and Big Life UK through all channels, including online and offline donations, purchases, or email newsletter sign-up requests (the “Services”).
Biglife.org is operated by Big Life Foundation USA, a 501(c)(3) nonprofit organization (EIN 27-3455389) based in Washington, United States on behalf of Big Life Foundation USA as well as Big Life Foundation Canada, a registered Canadian charity (# 812720-4), and Big Life UK, a registered UK charity (# 1158772), together "Big Life" or “we”.
For the purposes of the applicable data protection law, including the GDPR, Big Life UK (registered charity # 1158772, whose registered office is at c/o Chapel & York Ltd, Unit 12 Ladycross Business Park, Hollow Lane, Dormansland, Surrey RH7 6PB, United Kingdom), Big Life Foundation USA (EIN 27-3455389, whose registered office is at 1715 N Heron Drive, Ridgefield, Washington 98642, United States), and Big Life Foundation Canada (registered charity # 812720-4, whose registered office is at 17474 Humber Station Road, Caledon, Ontario l7E 0Z2, Canada) are joint data controllers for the processing of your personal data.
PERSONAL DATA WE COLLECT
Big Life may collect certain information as listed below relating to you as an identified or identifiable natural person (“Personal Data”).
Personal Data we collect depends on how you use our Services. We may collect these Personal Data from you through your use of our Services notably by entering into form fields, when signing up for our e-newsletter, making a donation or making a purchase in on our online store.
We aim at keeping the Personal Data we hold accurate and up-to-date. Please ensure that the Personal Data you communicate is accurate and update them whenever necessary.
As a visitor to our Services, Big Life’s servers automatically record certain Personal Data, such as your Internet Protocol ("IP") address (so we understand which country you are connecting from when you visit our Services), your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Services.
Signing Up for our Email Newsletter:
To receive communications about Big Life programs and initiatives, we offer through our Services newsletter or email subscription services. Our sign-up form requests Personal Data via a secured third-party service that complies with GDPR mandatory requirements.
Making a Donation:
When you make an offline donation or an online donation on biglife.org, we collect Personal Data such as your name, billing address, email address, and phone number. We collect information about your donation, including any comments you may include and the amount of your donation. We also collect (but do not retain) credit card numbers which are processed by a third-party payment vendor subject to the Payment Card Industry Data Security Standards. If you use PayPal or a similar service, their use of your Personal Data is based on their terms of service and policies, not ours, so we encourage you to review those policies carefully.
When you make an online purchase on our Services, we may collect your Personal Data such as your name, billing address, shipping address, email address, and phone number. We also collect (but do not retain) credit card numbers which are processed by a third-party payment vendor subject to the Payment Card Industry Data Security Standards. If you use PayPal or a similar service, their use of your Personal Data is based on their terms of service and policies, not ours, so we encourage you to review those policies carefully.
Donations in Honor/Memory of Someone:
When you make a donation in honor or memory of a loved one, we collect payment and contact information about you, as well as the name, email address, and/or mailing address of the recipient as provided by you.
Contests, Promotions, and Surveys:
Periodically, Big Life may invite you to participate in contests, take advantage of special promotions, or complete online surveys. Personal Data we collect from these contests, promotions, and surveys may be associated with you personally.
HOW WE USE YOUR PERSONAL DATA
Big Life collects, uses and stores Personal Data that you provide or we obtain in order to provide you with our Services, notably, to:
- Process your purchases made in our online store, contact you regarding any questions related to your purchase, and/or ship the item(s) you have purchased. Use of this Personal Data is necessary for the performance of the contract between you and us in connection with your purchase. If you do not provide the necessary Personal Data to us or our payment service provider, we will not be able to process your purchase.
- Process your donations, contact you regarding any questions related to your donation, and/or ensure that Gift Aid can be claimed (if you are eligible). Use of this Personal Data is necessary for the performance of the contract between you and us in connection with your donation. If you do not provide the necessary Personal Data to us or our payment service provider, we will not be able to process your donation.
- Comply with our legal obligations (for example, we are required to pass relevant Personal Data to local tax authorities (i.e., HMRC) or other competent authority for Gift Aid claims).
Big Life may also collect, use and store Personal Data as necessary for certain legitimate interests, which include the following:
- Notifying your friends and family about your donation in their honor if you ask us to do so;
- Using the technical information logged by our servers when you use our Services (described above) to improve your experience on our Services (such as remembering your name, the items in your Cart, or your preferences) and preventing fraudulent activity;
- If you ask us to delete your Personal Data or to be removed from our email lists and we are required to fulfil your request, we will keep basic Personal Data to identify you and prevent further unwanted processing;
- Operating our Services and our business; and
- Compiling aggregate statistics that allow us to understand how visitors or registered users use our Services, and to make improvements in design and content to better serve you.
HOW WE SHARE YOUR PERSONAL DATA
We will share your Personal Data with our agents, representatives, service providers and contractors located within and outside of the UE and the EEA in order to process your donations, offer you services in connection with our Services, communicate news and information about Big Life claim Gift Aid from the UK government, and complete financial transactions.
Unless you ask us not to (please refer to section “Your rights” below for more details), we may share your Personal Data under the following circumstance:
- When you make a donation that is part of a campaign sponsored by your employer, and/or when your employer is being asked to match your donation, we will share your name, email address and the amount of your donation with your employer.
When required or permitted by applicable law, we may also use or disclose your Personal Data to limited third parties in the following circumstances: (1) we need to respond to a subpoena, court order, or legal process, including to meet national security or law enforcement requirements; (2) an emergency situation requires disclosure before your permission can be obtained (e.g., situations involving potential threats to personal safety),or; (3) we determine that disclosure is needed to protect our rights or property, or the rights or property of another person. In such events, we will implement appropriate safeguards to ensure that your Personal Data is protected.
We may share aggregated demographic and statistical information with our other partners. This is not linked to any Personal Data that can identify any individual person.
TRANSFER, PROCESSING AND STORAGE OF PERSONAL DATA
As a global organization with affiliated entities located inside and outside of the EU and the EEA, Big Life may transfer your Personal Data to any Big Life affiliate outside the EU and/or the EEA or for purposes described in the section “How we share your Personal Data” above, on behalf and under control of Big Life, including for storage on servers of our hosting service providers in the United States.
Big Life implements cross-borders transfers in compliance with applicable privacy and data protection regulations, including Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data (“GDPR”). Where mandated by applicable law, to ensure that your Personal Data does receive an adequate level of protection, Big Life implements the appropriate measures to ensure that your Personal Data is treated across the EU and/or the EEA by the aforementioned parties in a way that is consistent with and which respects the applicable privacy and data protection laws. Measures may notably include a data transfer agreement and/or fall within the scope of the Privacy Shield Framework.
Privacy Shield Framework
Big Life has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to the JAMS PRIVACY SHIELD, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.
Under certain limited conditions, if your complaint is not resolved through these channels, it may be possible for individuals to invoke binding arbitration before the Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction. Big Life will comply with all investigations and enforcement powers of the Federal Trade Commission (FTC) with respect to Personal Data received or transferred pursuant to each Privacy Shield Framework.
Big Life is responsible for the processing of Personal Data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf (described under the "Disclosure of Personal Data" section above). We comply with the Privacy Shield Principles for all onward transfers of Personal Data from the EU and Switzerland, including the onward transfer liability provisions.
INFORMATION ABOUT CHILDREN
Big Life designs its Services for a general audience and does not collect Personal Data about your age. We may, from time to time, partner with other organizations to educate children about our work. In those cases, we do not collect Personal Data from a visitor on pages specifically designed for children.
Upon your request in accordance with the “Contact Us” section below, and subject any relevant legal requirements and exemptions and, as the case may be proof of your identity, you may:
- Access your Personal Data: We may provide you with a copy of any Personal Data that we have on file for you. You can request us to make changes to your Personal Data and update your account at any time. We do our best to keep your Personal Data accurate and up to date, to the extent that you provide us with the information we need to do so. If your Personal Data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes.
- Erase: You may have your Personal Data removed from our system. For privacy and security, requests must come from the email address tied to your account.
- Rectify your Personal Data: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where applicable and possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Restrict the processing of Your Personal Data: You may 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 (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Exercise your right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in order to (i) (a) perform our contract or (b) when you gave us your consent to the processing and (ii) such processing is implemented by automated means. We will give you your Personal Data in a structured, commonly used, and machine-readable format. You may reuse it elsewhere.
- Object to the processing of your Personal Data: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are processing your Personal Data for direct marketing.
Withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your Personal Data that has already taken place.
- Lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can lodge a complaint with the competent supervisory authority (i.e. Information Commissioner's Office (ICO) (UK) (details on how to do so can be found on the ICO's website), Office of the Privacy Commissioner of Canada (Canada), Federal Trade Commission (US), or other data protection authority that is authorized to hear those concerns).
In addition, we will give you the opportunity to tell us not to publish your Personal Data on our Services or in our annual report. You may ask us to change the anonymous settings on past donations.
We will make reasonable efforts to comply with the aforementioned requests within thirty (30) days, unless such requests are prohibited by law, or there is a legitimate purpose to retain your Personal Data, in which case we will inform you without undue delay. We reserve the right to verify your identity before any request relating to your Personal Data processed by us. Please direct any questions about your Personal Data using the contact details provided at the end of this Policy.
We will retain your Personal Data for only as long as needed to fulfill the purposes for which it is collected. We may also retain and use your Personal Data in order to comply with our contractual or legal obligations, audit requirements, resolve disputes, and prevent abuse.
YOUR PRIVACY AT A GLANCE
Big Life’s Privacy Practices at a Glance
Relevant Personal Data
Donation processing, one time or monthly (Ranger Club)
necessary for the performance of a contract
Name, billing address, phone number, email address
for as long as needed to fulfill the purposes for which it is collected
E-store purchase processing
necessary for the performance of a contract
Name, billing address, shipping address, phone number, email address
for as long as needed to fulfill the purposes for which it is collected
E-news subscription processing
consent/legitimate interest of Big Life to maintain supporter relationships
Name, email address
for as long as needed to fulfill the purposes for which it is collected
LINKS TO OTHER WEBSITES
Our Services may provide links to other third-party websites and features that are not owned or controlled directly or indirectly by Big Life. We are not responsible for the privacy practices of third parties, which are subject to their respective privacy policies.
Should you wish to take additional steps to safeguard your Personal Data online, to learn more about how to protect yourself, visit the Federal Trade Commission website (US), Office of the Privacy Commissioner of Canada (Canada), or the Information Commissioner's Office (UK).
SAFEGUARDING YOUR INFORMATION
Big Life understands the importance of keeping your information secure and confidential. We take reasonable and appropriate measures to protect your Personal Data from unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the Personal Data provided to us through our Services.
Big Life also relies on reasonable measures to safeguard Personal Data in our possession:
- Enforcement of group-wide policies and procedures on Personal Data use, security and confidentiality;
- Restricting access to Personal Data to only those employees and third-party service providers on a “need to know” basis and under strict confidentiality requirements;
- Use of technologies to safeguard Personal Data during transmission, such as SSL encryption for some of the data that you provide via our Services and using appropriate security measures to safeguard the Personal Data we process;
- Use of industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our computer systems and networks.
Where such changes are substantial, we will also notify you by other means prior to the changes taking effect, such as by sending you an email notification or through the Services. By continuing to use our Services thirty (30) days after such revisions are in effect, you will be deemed to accept and agree to the revisions and to abide by them.
For individuals in the European Union, Big Life has appointed Big Life UK as Big Life’s representative in the European Union, pursuant to Article 27 of the GDPR. You may contact Big Life UK at: c/o Chapel & York, Unit 12 Ladycross Business Park, Hollow Lane, Dormansland, Surrey RH7 6PB, United Kingdom and address any issues relating to processing by Big Life to Big Life UK.
Big Life Foundation USA
1715 N Heron Drive
Ridgefield, WA 98642
Phone: +1 971-322-3326
Big Life UK
c/o Chapel & York Ltd
Unit 12 Ladycross Business Park
Surrey RH7 6PB
Big Life Foundation Canada
17474 Humber Station Road
Caledon Ontario L7E 0Z2
LAST MODIFIED: June 7, 2019