Kusasa asbl, and the people we seek to help, are dependent on the generosity of our supporters as well as the goodwill and trust of the public. We (Kusasa) are therefore committed to protecting any personal information we obtain about you, whether you are just visiting our website or are a financial supporter, volunteer or campaigner. This Privacy Policy sets out how we obtain, use and protect any personal information you provide to us, whether online, via phone, text, email, in letters or in other correspondence.

Who we are

Kusasa is an international non-profit organisation supporting marginalised girls to have access to higher education and thereby tackling the issues of inequality and empowering young women to step up as leaders of change and make a contribution to their country’s economy and community.

The processing of your personal data is carried out by or on behalf of Kusasa Asbl (known hereafter as ‘Kusasa’). Kusasa is a non-profit organisation, registered in Luxembourg (F44113).

If you have any questions or concerns regarding our Privacy Policy or our processing of your personal information, please contact:

Kusasa Asbl

1 Rue du Cimetière,

3396, Roeser,

Luxembourg

Or by email: info@kusasa.africa.

Our privacy policy takes into account several legal instruments, including:

• Directive 2009/136/EC of 25 November 2009 (“The European Union Cookie Directive”)
• General Data Protection Regulation (GDPR) (EU) 2016/679

Contents

This privacy policy explains the following:

• How we collect and process personal data of our supporters
• How we collect and process personal data of job applicants
• How to request to see the data we hold about you
• How to change your marketing preferences or update the information we hold about you
• Security Policy
• Retention policy
• Cookie Policy

How we collect and process personal data of our supporters

We can collect personal information to allow us to provide you with information on our activities and services that we believe will be of benefit. Under the new data protection law this is referred to as ‘Legitimate Interests’.

Legitimate Interests means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests. When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will 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).

What data do we collect	Purpose / why we collect it
If you have signed up to receive our newsletter and occasional reminders about our campaigns, we will collect your name and email address.	This data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The data is stored in our website, which is only accessible to staff by means of password access. This data is shared with a third-party: Mail Chimp, also hosted outside the EEA, who send out the newsletter on our behalf. We will process the data because you gave us consent.
If you contact Kusasa to make a donation, we will collect and process data relating to the financial transaction to enable us to process the donation and for our financial records. Depending on the method used to contact us, this data may include: Name, Email address, Postal address, Telephone and/or mobile number, bank account details, Credit card details, employer details and taxpayer status.	For setting up a regular donation, for processing credit card payments, for processing a payroll gift and for claiming Gift Aid. The legal basis for this is legitimate interest.
If you have made a donation to us through one of the third parties with whom we work (e.g. GoFundMe), and consented for your information to be shared with us, we may receive your personal details for our marketing purposes.	These independent third parties will only do this when you have indicated that you wish to support Kusasa and with your consent. Please check their Privacy Policy when you provide your information to understand fully how they will process your data.
If you have expressed an interest in participating in a specific fundraiser for us in a sponsorship capacity, we may collect “sensitive personal data” about you, such as age and/or gender.	This is to ensure that we provide appropriate facilities or support to enable you to complete the event. The legal basis for processing this is your explicit consent.
If you are simply browsing our website as an anonymous visitor, Kusasa may still collect certain information from you, such as your IP addresses, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths.	The source of the data is our analytics tracking system and the lawful basis for this processing is our legitimate interest in monitoring and improving our website.
We may collect aggregated or anonymous information when you visit our website or interact with our content. For example, we may collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our website or view and interact with our ads and content.	Please see our Cookie Policy for more detail. The source of the data is our analytics tracking system and the lawful basis for this processing is our legitimate interest in monitoring and improving our website.
We may also collect and process information about your interactions with us, including details about our contacts with you through email, SMS, post, on the phone or in person (i.e., the date, time, and method of contact), details about donations you make to us, events or activities that you register for or attend and any other support you provide to us.	The lawful purpose for processing this data is our legitimate interest in communicating effectively and in an informed manner with you, and administering your account with us.
Kusasa may also use publicly available information such as wealth screening to identify people who express an interest in giving major gifts to organisations like Kusasa, or who may be interested in a high profile public association with Kusasa. This information may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from other sources.	During the initial stages of our research, the lawful basis for the processing of this data is our legitimate interest. For Kusasa to continue supporting our current beneficiaries and further expand our reach, we need to find new supporters and raise more money. Without doing research to find people who might be interested in donating to, or partnering with us, we can only do ‘mass’ fundraising (door drops, advertising) which is untargeted, expensive, and a less efficient use of charity resources.
Kusasa uses cookies, for more information please see our cookie policy.
We may combine the information that we collect about you from publicly-available sources, and analyse what we know about your interests, preferences and level of potential engagement or donation We carefully manage the communications we send you to ensure that we are contacting you in the most appropriate way and that we are not sending you unwanted communications.	We may also use statistical analysis to analyse this data and understand the likelihood that you will be interested in or responsive to a campaign or message. We may use third party service providers to assist us in this process. The lawful purpose for processing this data is our legitimate interest in ensuring that our communication with you is relevant and tailored to your background and interests.
Kusasa collects and process personal data of beneficiaries.	The lawful process for processing this data is our legitimate interest in tracking the number of beneficiaries and the justification of their selection to meet Kusasa’s organisational objectives to support the poorest and most marginalised girls. It is also necessary in order to carry out monitoring that the beneficiaries receive everything that they are entitled to and that they are continuing to attend school/college.

How we collect and process personal data of job applicants

If you apply to work at Kusasa, we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside Kusasa – for example, if we need a reference, plan to use an external supplier to run background checks or need to get a ‘disclosure’ from the Disclosure and Barring Service (DBS) – we will make sure we tell you beforehand, unless we are required to disclose this information by law. If you are unsuccessful in your job application, we will hold your personal information for 12 months after we’ve finished recruiting the post you applied for. After this date we will destroy or delete your information.

Sharing your personal data

We will never sell your details and will only share your details with third parties (who are not service providers working at our direction) if you ask us to. We use secure and trusted commercially available CRM and marketing automation software. We will not make cold telephone calls to members of the general public and, therefore, will not purchase your data in order to do so. We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect Kusasa, for example in cases of suspected fraud or defamation, or in order to comply with any other applicable legal obligation.

How to request to see the data we hold about you

Under the General Data Protection Regulations and Data Protection Act you have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. This is known as a subject access request (SAR). We will respond to a subject access request without undue delay and in any event within one month of receipt of the request. Please address requests and questions about this or any other question about this Privacy Policy to info@kusasa.org.

How to change your marketing preferences or update the information we hold about you

You can change any of your marketing preferences at any time (including telling us that you don’t want us to contact you for marketing purposes) by:

• Indicating that you do not wish to receive our marketing emails by clicking the ‘unsubscribe’ link in at the end of our marketing emails;

• Contacting us through by email: info@kusasa.africa, or by writing to us at: Kusasa Asbl, 1 Rue du Cimetière, 3396, Roeser, Luxembourg.

• If you have indicated that you do not wish to be contacted for marketing purposes, we will maintain your details on a suppression list to help ensure that we do not continue to contact you for marketing purposes. However, we may still need to contact you for administrative purposes, including (but not limited to):

• Processing a donation you have made and any related Gift Aid;
• Providing you with the information you need in order to participate in an activity or event for which you have registered (e.g., a race) and
• Explaining and apologising where we have made a mistake.
• Similarly, if your contact details have changed or you think any information we have about you is incorrect or incomplete, you can always update or correct the information we hold about you by contacting us through our team as explained above.

Security Policy

We take appropriate physical, electronic and managerial measures, such as utilising Secure Sockets Layer (SSL) encryption, to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary. The Kusasa website may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including policies on their use of cookies, and we urge you to review them. They will govern the use of personal information you submit or which is collected by cookies whilst visiting these websites.

Retention policy

We will hold your personal information on our systems for only as long as is necessary for the relevant activity, e.g. we will keep a record of donations for as long as financial regulations require. If you request us not to send you marketing information we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

Right to lodge a claim

You also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.

Cookie Policy

1. What is a cookie?
   Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device and to target the content displayed to the user’s interests. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. You can find more information about cookies at: www.allaboutcookies.organd www.youronlinechoices.eu. For a video about cookies visit https://www.cookielaw.org/blog/2011/11/22/good-to-know-about-google/.
2. Why does Kusasa use cookies?
   Like many websites, Kusasa uses cookies in order to provide you with a more personalised web service. Cookies help us identify which bits of our website people are using, and help us do work on those sections of the website to improve the user experience. We also use cookies to help show content on our site which is relevant to you and your interests, for example if on a previous visit you went to our pages about emergencies, festivals or events, we might find this out from your cookie and show you other information on our website related to emergencies, festivals or events on subsequent visits. Information supplied in cookies also allows us to measure the effectiveness of online marketing campaigns for Kusasa. This enables us to ensure any money we spend on digital marketing gives us a good return on investment.
3. Further information on Kusasa cookies and how to control your cookie preferences
   A list of the main cookies that we use and what each is used for, together with ways to control your cookie preferences can be found in our cookie policy.

Notification of change of Privacy & Cookie Policy

This Privacy & Cookie Policy may change from time to time. Please visit our website periodically in order to keep up to date with the changes in our Privacy Policy.

Last Update: July 2018