Efficient Appliances for People & the Planet

Menu

UK and EU Website Privacy Policy

Introduction

This Privacy Policy sets out how CLASP uses and protects your personal data.  This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.  Alternatively, you can view the full version of the Privacy Policy here [insert relevant link].

  1. IMPORTANT INFORMATION AND WHO WE ARE (Paragraph 1)
  2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (Paragraph 2)
  3. HOW IS YOUR PERSONAL DATA COLLECTED? (Paragraph 3)
  4. HOW WE USE YOUR PERSONAL DATA (Paragraph 4)
  5. DISCLOSURES OF YOUR PERSONAL DATA (Paragraph 5)
  6. INTERNATIONAL TRANSFERS (Paragraph 6)
  7. DATA SECURITY (Paragraph 7)
  8. DATA RETENTION (Paragraph 8)
  9. YOUR LEGAL RIGHTS (Paragraph 9)
  10. CONTACT DETAILS (Paragraph 10)
  11. COMPLAINTS (Paragraph 11)
  12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (Paragraph 12)
  13. THIRD PARTY LINKS (Paragraph 13)

1. Important Information and Who We Are

Privacy Policy

This Privacy Policy gives you information about how CLASP collects and uses the personal data of those types of individuals set out below and explains your privacy rights when we interact with you in the ways explained in this Privacy Policy:

  1. visitors to this website, (the “Website”);
  2. donors;
  3. business contacts;
  4. suppliers and service providers;
  5. marketing contacts; and
  6. social media contacts who interact with us through our social media accounts.

This Website is not intended for children and we do not knowingly collect data relating to children.

Controller

CLASP NGO Ltd., (company registration number 16382945), of Suite 1, 7th Floor, 50, Broadway, London, United Kingdom, SW1H 0DB, is the controller and responsible for your personal data (“CLASP“, “we“, “us” or “our“).

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (Paragraph Error! Reference source not found.), please contact us using the information set out in the contact details section (Paragraph Error! Reference source not found.).

2. The Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified.  We may collect, use, store and transfer different kinds of personal data about you, for example, personal data you may provide when you register with us, sign up to our newsletter or other marketing materials, make a donation to us, purchase a product or service from us, or take part in a competition or other promotional activity.

We have grouped together the different kinds of personal data about you which we collect, use, store and transfer as follows:

  • Identity Data includes first name, last name, any previous names, marital status, title, date of birth and gender.
  • Contact Data includes home address, work address, billing address, delivery address, email address (work and personal), telephone numbers (work, personal and mobile) and company name.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address (which we may associate with your domain name or that of your internet service provider), your login data, browser type, version and settings, time zone setting and location, browser plug-in types and versions, operating system, settings and platform, device ID and details of the other technology or the devices you use to access this Website, or our products and services.
  • Profile Data includes your username and password or similar identifier, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you interact with and use our Website, products and services, for example, information about the referring page that linked you to our Website, the pages, content or advertisements you see or click on during your visit (and when and for how long you do so), items you download, the next website you visit when you leave our Website, any search terms you have entered on the Website or a referral website and data collected by cookies.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Location Data includes real-time feeds of your appliances or devices.
  • Due Diligence Data includes background information in respect of vendors collected for due diligence purposes.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.  For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific Website feature in order to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering.

We do not collect any of the following special categories of personal data, or criminal offence-related data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, or information related to criminal offences and convictions.

Where we ask you to provide personal data, we will indicate whether this is required (e.g. where we need to collect personal data by law, or under the terms of our contract with you, or whether the provision of personal data is optional).

You may choose not to provide us with personal data that we request.  However, some of this information may be necessary for us to interact with you in the ways you have requested, (for example, we may not be able to respond to your enquiries, provide you with additional information or publications, enter into agreements with you or accept your donations).

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Your Interactions With Us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:
  • request our products or services;
  • create an account on our Website (if/when applicable);
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us (e.g., when you email us with any questions or comments).
  • Automated Technologies or Interactions. As you interact with our Website, we will automatically collect certain Technical Data and Usage Data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our Cookie Policy [insert relevant link] for further details.
  • Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties and public sources as set out below :
  • Technical Data is collected from the following parties (which may be based inside or outside the UK and the EU):
  • analytics providers, such as Google;
  • advertising networks; and
  • search information providers.
  • Contact Data is collected from providers of technical services, such as [insert relevant names].
  • Identity Data and Contact Data is collected from data brokers or aggregators, such as [insert relevant names].
  • Identity Data and Contact Data is collected from publicly available sources, such as Companies House and the Electoral Register, based inside the UK.

Although we use social media platforms in the course of our activities, except as otherwise expressly provided in this Privacy Policy, we do not collect or request personal data through such platforms (although occasionally we may inadvertently be provided with unsolicited personal data in this way).  We moderate or remove comments that include personal data from our social media accounts and no such data will be retained in our system or shared with third parties.

4. How We Use Your Personal Data

Legal Basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Contract Performance: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate Interests: We may use your personal data where it is necessary to conduct our organisation and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience.  We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal Obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

Purpose/Use Type of Data Legal Basis
To provide Website functionality, content and information. Identity Data; Contact Data; Technical Data; Profile Data; Usage Data; and Location Data Legitimate Interests (processing is necessary to operate our Website and provide information about our products and services).
To ensure Website security and protection (including through monitoring the Website) and to prevent fraud. Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; Profile Data; Usage Data; Marketing and Communications Data; and Location Data Legal Obligation (processing is necessary for compliance with legal obligations to which we are subject, for example applicable data protection and cybersecurity-related legislation). Legitimate Interests (processing is necessary to protect our systems and users, maintain network security and prevent fraud).
To administer, operate, maintain and protect our organisation and Website (including troubleshooting, testing, system maintenance, support, reporting, hosting of data, resolving technical issues and Website optimisation). Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; Usage Data; and Location Data Legitimate Interests (processing is necessary for maintaining Website performance, operating our organisation, providing administration and IT services and, improving the user experience).
To analyse Website and related data in order to improve our Website, products, services, customer relationships and experiences, to monitor performance, to measure Website effectiveness, to understand user behaviour and preferences and to measure the effectiveness of our marketing and communications. Identity Data; Contact Data; Technical Data; Profile Data; Usage Data; Marketing and Communications Data; and Location Data Legitimate Interests (processing is necessary to improve Website functionality, online presence and user experience, to study how customers use our products and services, to develop and improve them and our organisation, to grow our organisation and to inform our marketing strategy).
To register you as a customer. Identity Data; and Contact Data Legitimate Interests (processing is necessary for registering you as a customer).
To process and deliver your requests for our products or services, including: (i) managing payments, fees and charges; and (ii) collecting and recovering money owed to us Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; and Marketing and Communications Data Contract Performance (processing is necessary to perform the contract for the provision of our products or services that we have entered into with you). Legitimate Interests (processing is necessary for our legitimate interests in delivering our products and services to you, collecting payments for such products and services and recovering debts due to us).
To conduct data field testing at your request regarding devices or appliances that are owned and/or operated by you. Identity Data; Contact Data; Technical Data; Usage Data; and Location Data Contract Performance (processing is necessary for the performance of the contract that we have entered into with you regarding data field testing).
To manage and administer our relationship with you, including: (i) communicating and corresponding with you; (ii) notifying you about changes to our terms or privacy policy; and (iii) dealing with your requests, complaints and queries. Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; Profile Data; Usage Data; Marketing and Communications Data; and Due Diligence Data Legal Obligation (processing is necessary for compliance with legal obligations to which we are subject, for example, applicable data protection legislation). Legitimate Interests (processing is necessary for managing our relationship with you).
To communicate and correspond with our customers, donors and other business contacts and to maintain, administer and update our CRM systems and marketing and contact databases. Identity Data; Contact Data; Technical Data; Profile Data; Usage Data; and Marketing and Communications Data Legitimate Interests (processing is necessary for communicating and corresponding with our contacts).
To register you as a donor and to process and administer donations made by you. Identity Data; Contact Data; Financial Data; Transaction Data; and Marketing and Communications Data Legitimate Interests (processing is necessary to register you as a donor and to process and administer donations made by you).
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data. Identity Data; Contact Data; Technical Data; Usage Data; Profile Data; and Marketing and Communications Data Consent, having obtained your prior consent to receiving direct marketing communications.
To learn more about our customers so that we can personalise our offerings to them. Identity Data; Contact Data; Technical Data; Profile Data; Usage Data; and Marketing and Communications Data Legitimate Interests (processing is necessary to study how customers and contacts use our products and services and to help us improve and develop our products and services).
To enable you to participate in prize draws, competitions, surveys or other promotional activities (which may be offered by us alone, or together with third parties). Identity Data; Contact Data; Technical Data; Profile Data; Usage Data; and Marketing and Communications Data Legitimate Interests (processing is necessary for promotional activities).
To procure goods and services and manage contracts, performance and vendor relationships, including by processing necessary payments and managing accounts. Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; Marketing and Communications Data; and Due Diligence Data Legitimate Interests (processing is necessary to procure relevant goods and services, manage contracts, performance, and vendor relationships and payments, tax and accounting effectively).
To manage our social media presence, to share and promote content on social media, to run social media advertising campaigns and to respond to comments, messages and mentions on social media. Identity Data; Contact Data; Technical Data; Usage Data; and Marketing and Communications Data Consent (where appropriate). Legitimate Interests (processing is necessary to maintain our online presence, to engage with our audience and professional community, to promote customer service, to market and develop our services, to engage in thought leadership and to promote professional engagement).
To administer our necessary accounting, recordkeeping, backup and administrative needs. Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; Profile Data; Usage Data; Marketing and Communications Data; and Location Data Legitimate Interests (processing is necessary to maintain and administer appropriate accounts and records, maintaining insurance coverage and managing claims and to comply with applicable legal, regulatory and ethical obligations and our policies and procedures).
To establish, exercise or defend legal claims. Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; Profile Data; Usage Data; Marketing and Communications Data; Location Data; and Due Diligence Legitimate Interests (processing is necessary to establish, exercise or defend legal claims).
For internal reporting, analytics, quality assurance and training purposes. Identity Data; Contact Data; Financial Data; Transaction Data; Technical Data; Profile Data; Usage Data; Marketing and Communications Data; Location Data; and Due Diligence Legitimate Interests (processing is necessary to plan our operations, to monitor performance, to maintain service quality and improve processes).

Marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.  We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view as to which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us [insert relevant link].  If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to updates to our Terms and Conditions, or checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see [insert relevant link to Cookie Policy].

5. Disclosures of Your Personal Data

We may share your personal data where necessary with the parties set out below, in accordance with applicable law, for the purposes set out in the table “Purposes for Which We Will Use Your Personal Data” above.

Internal Personal Data Sharing

We share your personal data internally on a “need to know” basis.  Based on this principle, your personal data will be processed, as appropriate, by various operations and professional support teams, compliance functions and global IT and finance teams.

Personal Data Sharing With Third Parties

We will also share your personal data with certain third parties where required by applicable law, where necessary for the purposes set out above, or where we have another legitimate interest in doing so.  Access to personal data is limited to those third parties who have a business need to know.  They will only process personal data on our instructions and are subject to appropriate confidentiality obligations.

Third Party Service Providers, Contractors and Partners 

We will share your personal data with certain types of third-party service providers, contractors, partners and their sub-processors for the purposes set out above.  We enter into appropriate data processing or other data sharing agreements with such third parties, where required, (which require implementation of appropriate security measures to protect personal data in line with our policies and the processing of the relevant data for specified purposes in accordance with our instructions and applicable law and also prohibit use of your personal data for the relevant third parties’ own purposes).  Such third parties include:

  • IT services providers, including cloud storage providers, document management system providers, email services providers, marketing automation platforms, web analytics companies, CRM system providers, and other professional service providers who process data on our behalf (e.g., those providing data storage or disposal services, typing, photocopying, courier, or translation services);
  • professional advisers, including auditors, accountants, lawyers, insurers, bankers and consultants;
  • business partners, including co-sponsors;
  • communications platform providers and social media platforms;
  • banks, payment processors and other financial institutions; and
  • counterparties, adverse parties, related parties and their legal counsel, representatives and expert advisers.

Other CLASP Entities 

We will share your personal data with other CLASP entities and between our offices in the USA, the UK, the EU and various other jurisdictions: (i) as part of our regular reporting activities; (ii) for reorganisation or restructuring exercises; (iii) for system maintenance, support and hosting of data; and (iv) where required, as part of our regular communications with other CLASP entities, (e.g., by email).

Other Third Parties For Restructuring Purposes 

We may share your personal data with other relevant third parties, with appropriate protections, in the context of the possible sale, merger, acquisition, reorganisation, consolidation, or restructuring of the whole or part of CLASP’s organisation or assets (including in respect of dissolution, liquidation, winding-up, or bankruptcy proceedings), or the acquisition of or merger with other entities.

Prior to completion, we will share anonymised data to the extent possible.  Post completion, we will share your personal data with the other parties to the extent required by the transaction.  If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

Other Third Parties 

We may also share your personal data with other relevant third parties: (i) when we believe that disclosure is necessary or appropriate to prevent financial loss, including to address disputes or claims and to respond to persons holding a legal or beneficial interest; (ii) in connection with an investigation of suspected or actual fraud or illegal activity; (iii) when we believe that disclosure is necessary to protect our rights, property, or safety, or to protect the rights, property or safety of our employees, you, or others; (iv) to any other specific third parties listed in the table “Purposes for Which We Will Use Your Personal Data” above; and (v) as required by law or any applicable regulatory authority.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

As noted above, we share your personal data with other CLASP entities (e.g., for the provision of administration and support services by our staff) and may also transfer your personal data to service providers or other third parties that carry out certain functions on our behalf.  This may involve transferring your data outside the UK and/or the European Economic Area, (the “EEA”) to the USA [and [insert names of other relevant jurisdictions]].

Whenever we transfer your personal data out of the UK or the EEA to countries which have laws that have not been deemed by applicable law to provide a level of data protection: (i) not materially lower than that in the UK, (i.e., where transfers have not been deemed to meet the “data protection test” and been approved by regulations); or (ii) essentially equivalent to that in the EU, (i.e., where transfers have not been approved by adequacy decisions), as the case may be, we implement appropriate safeguards by entering into with the relevant data importers:

  • regarding the UK, either the UK International Data Transfer Agreement, (the “IDTA”), or the International Data Transfer Addendum, (the “Addendum”) to the European Commission’s standard contractual clauses for international data transfers, (the “SCCs”); and
  • regarding the EU, the SCCs.

To obtain further details and copies of any of these safeguards, please contact us at privacy@clasp.ngo.

7. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider 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 and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.  By law we have to keep basic information about our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for six (6) years after they cease being customers for certain tax and other purposes.

At the end of the applicable retention period we may destroy or erase from our systems, or anonymise, your personal data.  In some circumstances you can ask us to delete your data (see Paragraph 5 below for further information).

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

You have a number of rights under applicable data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “subject access request“). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Paragraph Error! Reference source not found. for further details).
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.  Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in Paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at privacy@clasp.ngo.

Automated Decision-Making

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.  This is permitted in certain limited circumstances and subject to certain conditions.  You have the right not to be subject to decisions based solely on automated processing (including profiling) that have legal or similarly significant effects on you, except where this is necessary for a contract with you, authorised by law, or based on your explicit consent.

You will not be subject to decisions that will have a legal effect on you or which will otherwise significantly impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.  We do not envisage that any decisions will be taken about you using automated means.  However, we will notify you in writing if this position changes.

Fees, Further Information and Time Limits

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one (1) month.  Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

10.Contact Details

If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address: privacy@clasp.ngo
  • Postal address: [
  • Telephone number: [insert relevant details]

11. Complaints

You have the right to make a complaint at any time regarding our personal data protection practices by contacting the relevant data protection supervisory authorities.  In the UK, this is the Information Commissioner’s Office (the “ICO”), the UK regulator for data protection issues (www.ico.org.uk), whose contact details are set out below.

UK Information Commissioner’s Office

Wycliffe House, Water Lane

Wilmslow, Cheshire

SK9 5AF

Telephone: 0303 123 1113

Fax: 01625 524510

Live Chat Service: (see “Make a Complaint” section of the ICO’s website located at www.ico.org.uk)

Before making a complaint, please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. Certain relevant data protection supervisory authorities, including the ICO, will expect you to have done this before reviewing your complaint.

If you are dissatisfied with the way we have handled your personal data (e.g., if you are unhappy with our response to a request that you have made to exercise your data protection-related rights), then you may make a complaint to us by emailing us at privacy@clasp.ngo.  You can access our Complaints Procedures here.

We will: (i) acknowledge receipt of your complaint within thirty (30) days of receiving it; (ii) without undue delay, take appropriate steps to respond to your complaint, including making appropriate enquiries, and keep your informed; and (iii) tell you about the outcome of your complaint as soon as possible (including why we have handled your complaint in the way that we did, what we have done to resolve your complaint and any actions that we have taken in response.

12. Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our Privacy Policy under regular review and may update it from time to time to reflect changes to our practices, legal requirements, or for other operational, legal, or regulatory reasons.  We will post a notice on our Website to notify you of any significant changes to our Privacy Policy in advance of the change taking effect and indicate when it was most recently updated.  This version was last updated on [insert relevant date].  Please review this Privacy Policy periodically to stay informed about how we protect your personal data.

It is important that the personal data we hold about you is accurate and current.  Please keep us informed by emailing us at privacy@clasp.ngo if your personal data changes during your relationship with us, for example a new address or email address, or if you become aware of any inaccuracies in the personal data that we hold about you.

13. Third-Party Links

This Website may include links to third-party websites (including websites of third party social media platforms, social networking platforms and blogging platforms), plug-ins, and applications, or to banners, widgets or advertisements that lead to other websites.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and are not responsible for their privacy statements and policies, which explain how the relevant third parties that provide them will use and protect your information.  When you leave our Website, we encourage you to read the privacy policy of every website you visit to learn about how your personal data is treated by others.  In accordance with the policies of third party social media platforms, social networking platforms and blogging platforms (and your privacy settings within your social media accounts), information about your activities on our Website (such as “likes” or “favourites”) may be published to your social media profile.