We take the protection of your privacy seriously. This Privacy Policy is designed to assist you in understanding how we collect and use the personal data we process and to assist you in making informed decisions when visiting our website (Website) and using our services (Services) (e.g., registering to our events, answering our forms and questionnaires, engaging with our marketing campaigns and giving your consent to receive our newsletters and emails).

We Respect Your Privacy

The Flourishing Circle (Company, we, our, us and flourishingcircle.org) knows that you (you, your, user and customer) care about how personal data is used, processed, and protected. We respect your privacy, and we are committed to protecting it through our compliance with this Privacy Policy (Policy).

This Policy should be read in conjunction with our Course Conditions and Terms of Service, into which this Policy is incorporated by reference.

Compliance

In compiling this Policy, we have taken steps to ensure we have incorporated the standards and principles outlined in data collection and privacy frameworks and applicable data protection law, including the European Union’s General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP).

Policy Scope

This Policy describes:

• The types of data you may provide, and we may collect when you use our Services.
• Our policies and practices for collecting, using, maintaining, protecting, and disclosing that information and data.

This Policy does not apply to services that are maintained or operated by third parties or other persons or entities with whom we have established financial, marketing, or other relationships. Our Services may link to third-party services, but these links are not endorsements of these services and this Policy does not extend to them.

Personal Data

You provide us with data that can be used to individually identify you from a larger group and include the information that you provide us like contact details (e.g., name, email address, address, phone number, country) and service transactions details (e.g., events you register for, payment details and any other information needed for completing donations and transactions).

We may also collect data from third-party sources (e.g., publicly accessible sources on the internet) to enrich and verify the data that you have provided or that we have collected about you. This data helps us to ensure that we have accurate records about you and will provide us with the ability to keep your data up to date. In some cases, we may use this data to determine something about you. For example, we may use your internet address to calculate your approximate geographic location.

Your Preferences

We want to provide you with relevant information according to your preferences. The communication that you receive from us will be in accordance with your preferences and this Policy.

When we provide subscription-based communications (e.g., email newsletters), we will allow you to make choices about your preferences at the point of information collection, or at any time after you have received a communication from us while you are subscribed to the service.

Subscription-based communications will not be sent to you unless you consent to receive them. After you request to receive these communications, you may opt-out of them at any time by selecting the “unsubscribe” link at the bottom of each communication. Please note that by opting-out you may affect other services which you have requested we provide to you.

Automated Data Collection

We automatically collect marketing and user experience details when you engage with our Services. We collect this data using automated tools that may gather information about your behaviour and your computer system (e.g., internet address, pages you have viewed, type of browser, user activity, content interests). This helps us understand the usage of our services and allows us to produce aggregate statistics on usage.

Some of the tools we use to automatically collect data, which include:

• Cookies. A cookie is a small data file transmitted from a website to your computer or device. We may use cookies on our Services to provide you with services and features. Cookies are not used to transmit data to third parties.
• Embedded Web Links and content. Links provided in our Services, and in some cases on third-party services may include tracking embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used.
• Embedded Content. Our Services may include embedded content (e.g., videos, images, articles, etc.) hosted on third-party services. Embedded content behaves in the same way as if you have visited third-party services.
• Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behaviour. If you choose to receive emails from Company, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our marketing partners may use Web Beacons to track your interaction with online advertising banners.
• Do Not Track (DNT) Disclosure. We do not track Services users over time and across third-party services to provide targeted advertising. Therefore, our Service does not operate any differently when it receives DNT signals.
• Google Analytics and tools. We use Google Analytics and tools on our Services to measure and evaluate the use (non-personal) of the Services or to protect online forms.
• Plug-Ins. We also use plug-ins on our Services for social networks (e.g., LinkedIn), which are indicated with a corresponding icon.

By using our Services, you agree to the use of these automated data collection techniques. If you do not want this, you must adjust the settings of your browser and email program accordingly.

Purpose of Information and Data Processing

Any data we collect from you is processed under the terms of this Policy and in the legitimate interest of our business and providing our Services to you as the lawful means for such processing.

Your data is collected and used to complete the services you have requested (e.g., registration to our programs and events, feedback questionnaires, subscription services).

We may also use data we collect to improve our Services to you and your experience when engaging with our Services.

Data Recipients

Our computers and data storage devices are in the European Union and Switzerland. Our hosting facility is in Switzerland. Some marketing-related data is stored in the United States of America by third parties complying with GDPR and FADP (e.g., Mailchimp). Some data collected automatically by our Services is collected in Google facilities around the world under Google privacy policy.

Transfer of data to third parties

Your data is neither transferred nor sold or otherwise transmitted to third parties in any form, unless this is required to process a contract with you or to fulfill our Services tasks, or if you have expressly consented to this in accordance with this Policy. In addition, your data may be transmitted to third parties if we are under obligation to do so by law or by an enforceable official or court order.

Data Retention

We retain your data for the time necessary to provide you the Services to which you have consented, and for so long as they are needed for the purposes for which it was collected, in accordance with this Policy, your rights, legal and regulatory requirements, or contractual arrangements.

Data Security

We take appropriate technological, physical, and organizational security precautions to protect your data against unauthorized access and misuse, alteration, and disclosure. We do these establishing processes, instruction, training, implementing IT and network security solutions, access controls and restrictions, encrypting data carriers and transmissions, pseudonymization and checks.

Access Accuracy of Your Data

For the purposes of this Policy and any related data, we operate as a data controller, unless otherwise determined by agreement or law.

You may always withdraw your consent to our use of your data, and you can exercise any of the following rights by notifying us as described below:

• Information: This Policy describes how we collect and use the personal data you provide to us and to assist you in making informed decisions when using our Services.
• Access: You may email us to request a copy of your data.
• Correction or Rectification: You can email us to request that we correct or rectify the data that you have provided to us. We may not accommodate a request to change your data if we believe the change would violate any law or legal requirement or cause your data to be incorrect.
• Erasure: Should you wish to cease use of our Services and have your data deleted from our Services ecosystem, then you may submit a request by emailing us. Upon receipt of such a request, we will confirm receipt and will confirm once your data has been deleted.
• Restrict Processing: When applicable, you may restrict the processing of your data by submitting a request to us via email. In your email, please explain how you wish us to restrict the processing of your data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent to the processing of your data.
• Portability: Upon request and when possible, we can provide you with copies of your data. You may submit a request to us via email. When such a request cannot be honoured, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
• Object to Processing: When applicable, you have the right to object to the processing of your data by submitting a request to us via email. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent to the processing of your data.
• Withdraw Consent: At any time, you may withdraw your consent for us to processing of your data by notifying us via email. Using the same email address associated with your Data, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your data. Where applicable, we will ensure such changes are shared with trusted third parties.
• Automated decision-making, including profiling: Personal data is not subject to any automated decision-making. We do not conduct profiling with personal data.
• Submit Complaints or Questions: If you wish to raise a complaint on how we have handled your data, you can contact us as described below. If you reside in a European Union member state or Switzerland, you may also complain to the supervisory authority in your country.

Agreement

Please read this Policy carefully to understand our policies and practices regarding your data and how we will manage it.

By visiting our Website, using our Services and providing your data, you are accepting and consenting to the practices described in this Policy and agree to its terms. If you do not agree with this Policy, then please do not visit our Website nor use our Services.

Changes to this Policy

We may amend this Policy without prior notice at any time. The version published on our website is the version currently applicable. If we make any changes to this Policy, they will be posted on this page. You can get to this page from our website by clicking on the Privacy Policy link. We will always date these changes, so you know if you are looking at a changed version.

Customer Service

We value your opinions and welcome your feedback. To contact us about this Policy please contact us at hello@flourishingcircle.org.

Status per August 2021