Privacy Policy

FundaçãoFocus AssistênciaHumanitária Europa (also known as Focus Humanitarian Assistance Europe Foundation) (“Focus Europe”, “we”, “us” or “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store and share personal data when you visit our website at www.focus-europe.org(the “Website”) or use any services offered via it (the “Services”). Please read this policy carefully. You are not required to “accept” this policy — it is provided for your information as required by applicable data protection law.

  1. APPLICABLE LAW

This policy is governed by and reflects the requirements of: (a) the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”); (b) the UK General Data Protection Regulation (“UK GDPR”) as retained in UK law by the European Union (Withdrawal) Act 2018; (c) the UK Data Protection Act 2018; (d) applicable Portuguese data protection law; and (e) any other applicable data protection and privacy legislation. References in this policy to “Data Protection Legislation” mean all of the above as applicable. References to “GDPR” mean the EU GDPR and/or UK GDPR as applicable to the relevant processing.

  1. WHO WE ARE / DATA CONTROLLER

The data controller responsible for your personal data is: Fundação Focus AssistênciaHumanitária Europa (also known as Focus Humanitarian Assistance Europe Foundation), registered in Portugalwith a UKestablishment. Focus Europe is registered with the UK Information Commissioner’s Office under registration number Z5965155.

  1. COLLECTION OF INFORMATION

Focus Europemay collect and process the following data about you:

  • Information that you provide to us. When using the Services, you may be asked to provide us with your information when you:
  • fill in forms on our Website, or correspond with us by phone, email or otherwise;
  • register to use our Services or at any subsequent point using our Services;
  • report a problem with our Website; or
  • complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).

Depending on the information and/or services you request, you may be asked to provide your name, email address, address, phone number, payment details and similar information.

  • Information we collect about you. With regard to each of your visits to our Website we may automatically collect the following information:
  • device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
  • technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
  • details of your visits to our website, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).
  • Information we receive from other sources. When using our Services, we may be in contact with third parties who may provide us with certain information about you in order to enable your use of the Services.

Our Website also collects information as you use the Website, regarding the pages that you visit and the clicks that you make. We do not, however, seek to link this information to your name and other identifying details if you provide them.

  1. PAYMENT PROCESSING

We use third-party payment processors to process credit and debit card payments made via the Website. Focus Europe doesnot store or have access to your full credit or debit card details. All payment data is handled directly by our payment processors in accordance with their own privacy policy and security standards. The sharing of your data with our payment processor is necessary for the performance of the contract between you and Focus Europe (Article 6(1)(b) GDPR). Your payment processor may be based outside the UK and/or EEA – please see the section on International Data Transfers below.

  1. HOW WE USE YOUR PERSONAL DATA AND OUR LAWFUL BASES

Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use in this policy. These are the principal grounds that justify our use of your information:

  • Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
  • Contract performance: where your information is necessary to enter into or perform our contract with you;
  • Legal obligation: where we need to use your information to comply with our legal obligations;
  • Vital interests: where we need to use your information to protect your vital interests;
  • Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
  • Legal claims: where your information if necessary for us to defend, prosecute or make a claim against you or a third party.

We use information held about you (and information about others that you have provided us with) in the following ways:

  • to provide you with access to our Website and to respond to your enquiries and requests (Lawful basis: Contract performance (Article 6(1)(b)); Legitimate interests (Article 6(1)(f)) – to operate the Website effectively);
  • to process donations made via the Website, including issuing donation receipts and acknowledgements(Lawful basis: Contract performance (Article 6(1)(b)); Legal obligation (Article 6(1)(c)) – e.g. financial record-keeping, Gift Aid compliance);
  • to comply with our legal and regulatory obligations, including anti-money laundering checks, Gift Aid record-keeping and financial reporting (Lawful basis: Legal obligation (Article 6(1)(c)));
  • to send you marketing communications about Focus Europeservices, eventsandinitiatives, where you have consented to receive them (Lawful basis: Consent (Article 6(1)(a)). See ‘Marketing’ section below);
  • to send you marketing communications about services or events organised by our partners or affiliates, where you have consented to receive them (Lawful basis: Consent (Article 6(1)(a)));
  • to ensure that content on our Website is presented in the most effective manner for you and your device, and to administer and improve the Website (Lawful basis: Legitimate interests (Article 6(1)(f)) – to maintain and improve our Website; Consent (Article 6(1)(a)) – to the extent non-essential cookies are used for this purpose);
  • to conduct internal research, data analysis and statistics to improve our services (Lawful basis: Legitimate interests (Article 6(1)(f)) – to understand how our Website is used and to improve it; processing uses only anonymised or aggregated data where possible);
  • to detect, prevent and investigate fraud and other criminal activity (Lawful basis: Legal obligation (Article 6(1)(c)); Legitimate interests (Article 6(1)(f)) – to protect Focus Europe and its donors from fraud);
  • to notify you about changes to our Services or this Privacy Policy (Lawful basis: Contract performance (Article 6(1)(b)); Legitimate interests (Article 6(1)(f)));
  • to protect the vital interests of any person where necessary (Lawful basis: Vital interests (Article 6(1)(d))); and
  • to establish, exercise or defend legal claims (Lawful basis: Legal claims (Article 9(2)(f) / Article 6(1)(f))).
  1. MARKETING

We may use your information for marketing Focus Europe’s own services and events, and those ofits affiliates, by regularly sending you newsletters by email. We will only send you marketing communications where you have consented to receive them (Lawful basis: Consent (Article 6(1)(a))).

We may also use your information to send you details about services which are being provided by our partners and affiliates, but only where you have consented to receive them (Lawful basis: Consent (Article 6(1)(a))).

We will provide an option to unsubscribe or opt out of further communication on any electronic marketing communication sent to you. You may also withdraw your consent at any time by contacting us at data@focusha.org. Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal.

  1. DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information (i) to organisations who work with us in providing the Website and the Services (such as analytics providers and Website developers), and/or partners and affiliates of Focus Europe; (ii)to complete your request to access the Services; or (iii)to outsource the hosting, administration or support of the Website or one or more of the other functions described herein (Lawful basis: Contract performance (Article 6(1)(b)); Legal obligation (Article 6(1)(c)); Legitimate interests (Article 6(1)(f))).

We may also disclose your personal information to third parties in the following circumstances:

  • if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets (Lawful basis: Legitimate interests (Article 6(1)(f)); Legal obligation (Article 6(1)(c)));
  • if we or substantially all ofour assets are acquired by a third party, personal information about our users will be one of the transferred assets (Lawful basis: Legitimate interests (Article 6(1)(f)); Legal obligation (Article 6(1)(c))); or
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Focus Europe, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection (Lawful basis: Legal obligation (Article 6(1)(c)); Legitimate interests (Article 6(1)(f))).
  • Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies (Lawful basis: Legal obligation (Article 6(1)(c)); Legal claims; Legitimate interests (Article 6(1)(f)) – to assist with the prevention of fraud and to assess your risk profile).

We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime (Lawful basis: Legal obligation (Article 6(1)(c)); Legal claims; Legitimate interests (Article 6(1)(f)) – to cooperate with law enforcement and regulatory authorities).

  1. INTERNATIONAL DATA TRANSFERS

Focus Europe is based in Portugal with a UK establishment. Some of your personal data may be transferred to, and stored or processed in, countries outside the UK and/or the European Economic Area (“EEA”), including the United States of America.

Where no adequacy decision covers the relevant country, we rely on appropriate safeguards such as Standard Contractual Clauses (EU) or the International Data Transfer Agreement or Addendum (UK) to ensure your data receives an equivalent level of protection. You may request further information about the specific safeguards in place by contacting us at data@focusha.org.

  1. HOW LONG WE RETAIN YOUR PERSONAL DATA

We retain personal data only for as long as is necessary for the purposes set out in this policy, or as required by law. The following indicative retention periods apply:

Where data is used for two purposes, we will retain it until the purpose with the later expiry date has been fulfilled, but will cease using it for the earlier purpose once that period has expired. Data that is no longer required is either securely and permanently deleted or irreversibly anonymised.

  1. YOUR RIGHTS

Under the EU General Data Protection Regulation (Regulation (EU) 2016/679) and the UK General Data Protection Regulation, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at data@focusha.org.

You have the following rights in relation to your personal data:

  • Right of access: You have the right to request a copy of the personal data we hold about you, together with information about how and why we process it.
  • Right to rectification: You have the right to request that we correct any personal data that is inaccurate or incomplete. We will use reasonable endeavours to ensure that your personal information is accurate, and you should notify us of any changes to the personal information you have provided to us.
  • Right to erasure (“right to be forgotten”): You have the right to ask us to delete all of your personal data. Doing so will result in Focus Europe deleting your personal data without undue delay, unless there is a legitimate and legal reason why Focus Europe is unable to delete certain of your personal data, in which case we will inform you of this in writing.
  • Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or object to our processing of it.
  • Right to data portability: You have the right to request that Focus Europe provides you with a copy of all of your personal data in a structured, commonly used and machine-readable format, and to transmit that data to another data controller, where it is technically feasible for us to do so.
  • Right to object: Where we process your personal data on the basis of legitimate interests, you have the right to object at any time. Where processing is for direct marketing purposes, the right to object is absolute and we will cease processing your data for that purpose immediately upon receipt of your objection.
  • Right to withdraw consent: Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time by contacting us at data@focusha.org or, in the case of marketing communications, by clicking the unsubscribe link in any email. Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal.
  • Right to complain to a supervisory authority: You have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (see www.ico.org.uk). In Portugal, this is the Comissão Nacional de Proteção de Dados (see www.cnpd.pt). You may also have the right to complain to the supervisory authority in your country of habitual residence or place of work.

Focus Europewill not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing, this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs. 

Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use our Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete.

  1. COOKIES

We use cookies and similar technologies on our Website. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy at https://focus-europe.org/cookie-policy/.

  1. PRIVACY POLICY CHANGES

Focus Europe may amend this privacy policy from time to time. We will post the revised policy on our Website so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Your continued use of our Website after the date that such notices are posted will be deemed to be your agreement to the changed terms.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcome. Please email us at data@focusha.org.

 

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