1.1 Welcome to the Pousaz Philanthropies’ privacy policy.
1.2 Pousaz Philanthropies’ respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you
2.1 This privacy policy aims to give you information on how Pousaz Philanthropies collects and processes your personal data through your use of this website, including any data you may provide through this website – should the site provide such functionality to users over time.
2.2 This website is not intended for children and we do not knowingly collect data relating to children.
2.3 It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
2.4 Pousaz Philanthropies Foundation (registration number 424) is the controller and responsible for your personal data (collectively referred to as “Foundation”, “we”, “us” or “our” in this privacy policy).
2.5 If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at info@pousaz.org.
2.6 You have the right to make a complaint at any time to the Jersey Office of the Information Commissioner (JOIC), the supervisory authority in the Bailiwick of Jersey for data protection issues (https://jerseyoic.org/). We would, however, appreciate the chance to deal with your concerns before you approach JOIC so please contact us in the first instance.
3.1 We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4.1 This website may include links to third-party websites, plug-ins and applications. Articles on this site may include embedded content also (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if you had visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
5.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
5.2 We may collect, use, store and transfer different kinds of personal data about you. Currently, this is limited to ‘Usage Data’, which is data collected by the website about how you use it.
5.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
5.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
6.1 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
7.1 We may use different methods to collect data from and about you including through:
Third parties or publicly available sources. We may receive personal data about you from third parties, such as technical data from analytics providers (eg Google Analytics).
8.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
9.1 We have set out below, in a table format, a description of the ways we plan to use 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.
9.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Legal basis |
| To administer and protect the Foundation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Technical | Our legitimate interests (eg to run the Foundation, for network security purposes etc) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Usage data | Our legitimate interests (eg to study how users use our site, and to help with its development) |
| To use data analytics to improve our website | Technical and Usage data | Our legitimate interests (eg to define types of users, to keep our website updated and relevant, to develop the Foundation and to inform our operational strategy) |
9.3 Legitimate Interest means our interests in conducting and managing the Foundation to enable us to provide the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
10.1 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
11.1 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
12.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
12.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
12.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
13.1 We may share your personal data with the parties set out below (acting as joint controllers, co-controllers or our processors, as the case may be) for the purposes set out in the table above.
13.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the 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.
14.1 EU territories, EEA territories and Adequate Third Countries are deemed by the European Commission to provide a suitable level of data protection. Adequate Third Countries are those territories in receipt of a European Commission ‘adequacy decision’, such as the United Kingdom, Isle of Man, Guernsey, Jersey, Japan and New Zealand. (The full list of these countries is available here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.)
14.2 References in this section to Third Countries meansa territory that is not an EU territory, EEA territory, or Adequate Third Country.
14.3 Currently, our website only collects Usage Data and certain Technical Data. The server hosting this data is located in the EU.
14.4 We do not currently transfer data that is the subject of this privacy policy to parties that are located in Third Countries.
14.5 In the event that we proposed to transfer your data to a Third Country, we will put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect Personal Data. Transfers may also be made pursuant to contracts in your interest or at your request.
15.1 We have put in place appropriate 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.
15.2 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.
16.1 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.
16.2 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.
16.3 In some circumstances you can ask us to delete your data: see below for further information.
16.4 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.
17.1 You have the right to:
17.2 If you wish to exercise any of the rights set out above, please contact us at info@pousaz.org.
18.1 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.
19.1 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.
20.1 We try to respond to all legitimate requests within one 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.