100 Million Campaign Privacy Notice
The 100 Million campaign is committed to ensuring every child is free, safe, and educated. We cannot claim to do that unless we ensure we protect the privacy of everyone who visits our website, decides to pledge their support, and becomes an active member of the campaign.
When you take our campaign pledge or take action with us to do all you can to ensure every child is free, safe, and educated, you provide us with your personal data. We take your commitment to this pledge seriously, and we make every effort to ensure the personal information you have provided when taking the pledge is protected.
Please spend a little time reading through this to make sure you understand how the 100 Million campaign supports your right to privacy. If anything is unclear, please get in touch with us and we will be happy to answer any questions you have.
Who are we?
We are the 100 Million campaign, and when it comes to your data we are officially called the ‘Data Controller’. The campaign is housed by the Kailash Satyarthi Children’s Foundation of America (KSCF-US), which is a registered non-profit organisation based in the United States. We operate worldwide, with offices and team members in India, the United States, and the United Kingdom.
The 100 Million campaign is based in the United States and in the United Kingdom.
In the United States, our registered address is:
1420 New York Avenue NW Suite 850, Washington DC 20005, United States
In the United Kingdom, 100 Million is legally housed by KSCF-US (UK registered number BR019642).
4.11 The Pill Box, 115 Coventry Road, London E2 6GG, United Kingdom
The person who oversees the data is called the Data Compliance Officer, and this person is Shaharazad Abuel-Ealeh, Communications Director for the 100 Million campaign. You can contact her with any questions you have about your data: email@example.com.
What information do we collect?
We collect the following types of personal information:
- Your name
- Your email address
- Your year of birth
- The country you live in
- The postal or zip code for where you live
- The language in which you would like to receive communications
- Your telephone number, if you choose to provide this
Where relevant or applicable, we also record:
- Your correspondence with us (for example, if you email us)
- Your participation with us (for example, if you choose to take action through one of our campaign emails)
- Photographs or videos you share with us
- Any username or password you have created to use some of the tools on our website
- Any other information you have chosen to share with us.
We collect the data in the following ways:
- Information you fill in on the website (including taking the 100 Million campaign pledge)
- Telephone or face to face conversations with you
- Local groups you may start or join
- Communication on social media
- Publicly available sources, like Companies House or the Charity Commission website.
Why couldn’t I take the pledge online?
As 100 Million is a worldwide campaign, we only ask for the data for which we have legal permission to collect.
At present, 100 Million does not collect data for anyone below the age of 13 – we’re sorry!
Some countries have very clear laws about what can be collected, and from whom. For example, some countries do not allow us to collect data from you if you are under the age of 16. If you live in a country where this is the law, then at present you will not be able to give us your data. As and when these ages change due to changes in the law, we will update the pledge form to be accessible to you.
However, you can ask your parent, teacher or guardian to take the pledge, and they can receive campaign information on your behalf.
How do we use personal information?
Your personal data helps us to ensure your interaction with the 100 Million campaign is empowering and well-supported. Examples of how we use your information include:
- Providing you with tools and information to help you as an active campaigner
- Updating you on our work and the work of other activists as part of the campaign worldwide
- Updating you on our policies, procedures, and legal obligations to you
- Personalisation of content or your experience online
- Carrying out polls and surveys
- Keeping a record of your relationship with the campaign
- Improving our services to you and developing the work of the campaign
- Investigating complaints or other issues.
What legal basis do we have for using your personal data?
100 Million needs a legal basis for using your personal data, under data protection laws which apply in different countries. 100 Million asks for your consent to use your data (for example, to allow us to send you campaign resources and news).
Can I withdraw my consent?
Yes you can – and you can withdraw consent, unsubscribe from our mailing list, change your preferences for receiving our emails, change your personal details, or request to transfer your details whenever you like.
You can do this either by getting in touch with our Data Compliance Officer (firstname.lastname@example.org) or, if you just wish to unsubscribe from emails, clicking the link which is at the bottom of every message we send.
If you are a citizen of the European Union, European Economic Area, or of the State of California, you can also request your right to be forgotten: this means your data will be deleted.
We will update your records as quickly as possible but it may take up to 45 days for our systems to update and stop messages being sent to you.
When do we share personal data?
We do not share or sell any personal information to third-party organisations for marketing or fundraising purposes.
We share your personal information with two different types of organisation:
- Our data processors: these are the organisations which provide the software for us to safely and securely store and manage your data, and to communicate with you.
- 100 Million campaign groups, which are based in your country. These campaign groups will be registered with the campaign, and are comprised solely of non-profit entities.
We share with the data processors so we can administer your relationship with 100 Million. The data processor cannot share or use your data for any other purpose, and we will always have contracts in place with any data processing company we work with.
We share with 100 Million campaign groups which are based in your country so that you can get involved in the campaigns and activities which are most relevant to you. These groups cannot share or use your data for any other purpose, and the 100 Million global team will provide safe and secure ways for them to communicate with you.
Where do we store and process personal data?
As 100 Million is a global campaign, it is possible that your data will be stored and processed outside of your home country.
Data is stored in the host country for the global 100 Million team. At present, this is the United Kingdom. This means your data is protected under the law of the United Kingdom and is compliant with the European General Data Protection Regulation (GDPR).
For citizens of the United States, data is processed in the United Kingdom in accordance with the GDPR, and in the United States in accordance with US CAN SPAM Act of 2003 and the US Communications Decency Act. Even though our charitable status means we cannot formally join, we also adhere to the principles contained within the Privacy Shield Framework.
For all other citizens, data is processed in the United Kingdom. If there are 100 Million campaign groups present in your country, your data may also be processed there by registered groups which have signed a formal agreement on the use of data, based on the GDPR.
How do we secure personal data?
100 Million uses technical and organisational tools and processes to protect your data and prevent the loss, misuse or alteration of your personal information.
Unfortunately the transmission of data over the internet is not 100% secure. We do our best to protect your personal data, but we cannot guarantee the security of your data when it is transmitted to our website. However, once we receive your information, we use strict procedures and security features to prevent unauthorised access.
How long do we keep your personal data for?
100 Million keeps your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.
We decide how long is appropriate to keep personal data. We do this by considering the amount, nature and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the legal requirements.
If you ask to receive no further contact from us, we will keep some basic information about you on our suppression list to avoid sending you more unwanted messages.
If you are a citizen of the European Union, European Economic Area, or of the State of California, and you request your right to be forgotten, your data will be deleted.
Use of automated decision-making and profiling
100 Million uses limited profiling and automated decision-making based on your interactions with the campaign.
Firstly, we organise data based on which type of campaigner you are:
- Activists: 13-25 year olds who have taken the pledge.
- Supporters: 26+ year olds who have taken the pledge.
These two groups receive different types of communications from us.
We also organise you based on your country and language:
- 100 Million operates in as many languages as possible, and we use the data you provide about your preferred language to send you appropriate communications.
- 100 Million also operates campaigns within different countries, not just at the global level, and so we use your country and zip code to find out if there is a national or local level campaign group you might be interested in.
Finally, if you choose to take action, get involved in any campaigns, or set up a group, we will record this information and personalise content and communications to improve our support for your involvement with the campaign.
How can I contact you?
You can get in touch with us in the following ways:
For data questions and requests: email@example.com
For campaign questions: firstname.lastname@example.org
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Using cookies is a very common practice and helps us to give you the best experience possible on our website. Cookies are harmless and cannot be used to run programmes or deliver viruses to your computer.
- Remember certain information about users so they don’t have to give the same information again
- Measure how people use our websites so we can improve the way information is provided
- From time to time, display adverts based on what parts of the 100 Million website you have visited
And finally, our disclaimer
Unfortunately, we cannot be responsible for any information you give in any public community areas of the 100 Million website, or on websites that we link to from our platforms. This information can be viewed or collected by any third party – but you should always be wary of publishing any personal information in public community areas.
You should also read the privacy notices of any other websites that we link to from our site which you visit. This is so you can understand what information is collected from you and for what purpose. 100 Million cannot be held responsible for the policies of any third party website that we link to, and you access these websites at your own risk.