Beteseb Felega – Ethiopian Adoption Connection Website Privacy Policy

Effective Date: 26 June 2022
Last Updated: 12 July 2022

Your privacy is important to Beteseb Felega – Ethiopian Adoption Connection, Inc. (referenced within this Privacy Policy as “BF-EAC,” “we,” “us,” or “our”). We developed this Privacy Policy to provide you with information concerning our personal data collection and usage, as well as our privacy and security practices when you visit our sites (collectively, “Site” or “Sites”); apply for a job with us; and/or provide us with personal data in connection with volunteering for or donating to BF-EAC.

Personal Data” means any information relating to an identified or identifiable natural person.

You” and “your” refer to the person reading this Privacy Policy (“Policy”), which may include adoptive parents, adoptees, Ethiopian family members, donors, volunteers, supporters, and other individuals visiting our Sites.

Processing” means any operation performed upon Personal Data, such as collection, storage, adaption, use, disclosure, and destruction.

 I. CATEGORIES OF PERSONAL DATA WE PROCESS

We will process the following categories of personal data when you use our website, volunteer for us, donate to us, and/or submit an application to work with us:

      • Personal Data that is Processed when You Communicate with Us. When you contact or interact with us through our Sites, email, or webforms, we collect your personal data, including your name and email address from you. When you contact us through the phone, we will collect your name and phone number.

Purpose and Legal Ground:

We process this personal data to contact you about services requested, to answer your questions related to our services and mission, and to handle any inquiries, suggestions,  or complaints that you may have.  The legal ground for processing this personal data for this purpose is BF-EAC’s legitimate interest in providing adoptee’s, adoptive families, Ethiopian families and supporters with customer support and monitoring the quality of our products and services.

      • Personal Data that is Processed when You Donate to Us. When you donate to BF-EAC, we will collect your personal data, including your name, email address, and the amount of your donation from you.  If you choose to dedicate your donation, we will collect the name of the honoree from you.  If you choose to send an eCard, we will collect the recipient’s name and email address from you.  If you donate with a credit card, your credit card information will be processed by one of our payment processors, which include PayPal, Stripe, and Zelle.  If you mail us an offline donation, we will collect your personal data including your name, mailing address, signature, financial institution, bank account number, and donation amount from your letter and check.

Purpose and Legal Ground:

(a)  We process your name, your email address, and the amount of your donation to provide you with a receipt for your donation.  The legal ground for processing your name and email address to provide you with a receipt, is our legitimate interest in providing our donors with proof of their support for our mission.

(b)  We process the name of the honoree to enable our donors to dedicate their donations.  The legal ground for processing the name of the honoree is our legitimate interest in facilitating meaningful charitable fundraising.

(c)  We process the personal data contained in your offline donation, including your name, mailing address, signature financial institution, bank account number, and donation amount in order to receive your donation from your financial institution.  The legal ground for processing this personal data is our legitimate interest in conducting effective charitable fundraising and enabling donors to support our organization.

      • Personal Data that is Processed to Provide You with Newsletters. When you sign-up for our newsletter, BF-EAC will collect your personal data, including your name, email address, and type of subscriber (e., adoptee, adoptive family, Ethiopian family, or other subscriber).

Purpose and Legal Ground:

We process this personal data to provide you with our newsletter.  The legal ground for processing this personal data for that purpose is your consent, which you may withdraw at any time by clicking the unsubscribe link in our newsletter.

      • Personal Data that is Processed to Provide You with Case Post Updates. When you sign-up for case post updates, FeedBurner will collect your personal data, including your email address and your role (e., as a subscriber or a subscriber and a podcaster).  We do not collect or process your personal data in collection with this processing operation.

Purpose:

The purpose of this processing is to provide you with updates regarding our Ethiopian Adoption Search Registry.

      • Personal Data that is Processed when You Purchase Products from Our Online Store with Zazzle. When you purchase a product from our online store with Zazzle, we collect your personal data including your name, country of residence, state of residence, and city of residence from Zazzle.

Purpose and Legal Ground:

We process this personal data to process your order and fulfill your purchase.  The legal ground for processing this personal data for that purpose is performance of a contract.  We may also process this personal data to detect potential fraud.  The legal grounds for processing this personal data for that purpose is our legitimate interest in protecting BF-EAC and you from attempts to engage in fraudulent transactions.

      • Personal Data that is Processed when You Register for Events. When you sign-up for one of our events, BF-EAC will collect your personal data including, your name, your payment service account name, the amount you paid to register for the event, and the number of children and adults in your party from you and Paypal.

Purpose & Legal Ground:

We process this personal data to ensure that enough food and seating is prepared for you and your party at our event.  When you pay to attend our event, the legal ground for processing this personal data for that purpose is the performance of a contract.  When you attend a free event or a paid event as part of another person’s party, the legal ground for processing this personal data is our legitimate interest in promoting our mission to reunite Ethiopian families and their adopted children through social gatherings.

      • Personal Data that is Processed when You Volunteer or Apply for a Job. When you volunteer your time or apply for a job with BF-EAC, we will collect your personal data, including your occupation, current or past job history, education history, and other employment-related data.

Purpose & Legal Ground:

We process this personal data to set up interviews and make volunteering and hiring decisions.  The legal ground for processing this personal data for that purpose is our legitimate interest in managing our volunteering and employment processes efficiently and verifying the identity and qualifications of job applicants and volunteers.

      • Personal Data that is Processed when You Browse and Interact with Our Site. If you browse or interact with our Sites, then we will place cookies on your computer or device’s hard drive through your web browser.  We will collect your network or connection information (such as IP address); browser type, browser version, browser language, device time zone, operating system, operating system version, location, time of visit, date of visit, page views, and clicks either directly from you or from a third-party provider through cookies.

Purpose & Legal Ground:

The types of cookies we use fit broadly into two categories.  The processing purposes and legal bases for each category are set out below.

Required Cookies:  These cookies are required for the site to perform basic functions, such as protecting your information or updating your donation information.  The legal ground for processing this personal data for this purpose is our legitimate interest in ensuring that our Sites function as intended and in a secure manner while honoring user’s choices and preferences.

Functional Cookies:  These cookies are used to analyze Site usage and performance and to perform other basic functions, such as remembering your location and language preferences.  The legal ground for processing this personal data is your consent, which you may withdraw at any time by clicking the “Manage consent” button at the bottom of each pageand moving the sliders in the Privacy overview to disabled.

For additional information, see the Cookies & Similar Technologies privacy notice, below.

II. RECIPIENTS OF PERSONAL DATA

We will transfer personal data to the following categories of recipients:

        • Electronic Payment Processors. If you donate to BF-EAC or register for an event, we will transfer your personal data, specifically your name and donation amount to PayPal, Stripe, or Zelle.  The purpose of this transfer is to (1) enable us to receive and process your donation or registration fee and (2) help prevent fraudulent transactions.  We do not directly process credit card data (e.g, credit card account number, card identification number), rather such data is collected directly from you by PayPal, Stripe, or Zelle.
        • Newsletter Service Provider. If sign-up for our newsletter, we will transfer your personal data, specifically your name, email address, and type of subscriber (e., adoptee, adoptive family, Ethiopian family, or other subscriber) to MailChimp.  The purpose of this transfer is to provide you with our newsletter.
        • Website Service Providers. If you browse or interact with our Sites, then we will transfer your personal data, specifically your network or connection information (such as IP address); browser type, browser version, browser language, device time zone, operating system, operating system version, location, time of visit, date of visit, page views, and clicks to our website service providers: our performance and security company CloudFlare, our other security company Sucuri, our website analytics service and email provider Google, our electronic payment processors, Stripe, Zelle, and Paypal, our website host WPEngine, and our platform and related software, WordPress. The purpose of this transfer is to ensure and improve the quality and functionality of our Sites.
        • Governmental entities and third parties in connection with legal matters. If BF-EAC (1) has your consent to transfer your personal data to governmental entities or other third parties in connection with a legal matter; (2) must comply with a valid subpoena, legal order, court order, warrant, legal process, or other legal obligation that covers your personal data; (3) is seeking to enforce any of our terms and conditions, policies, or other agreements; or (4) must transfer your personal data to pursue available legal remedies or defend legal claims, then we will transfer the relevant part of your personal data to a government entity or third party.

Recipient Industry, Recipient Location, and Purpose of Transfer:

The governmental entities could be courts, regulatory agencies, law enforcement agencies, security or intelligence agencies, or any other government entities with lawful authority to compel the transfer of your personal data.  The governmental entities will be a part of the public sector, and will be engaged in law enforcement, adjudication, intelligence, or other regulation.  The third parties could be law firms, expert witnesses, compliance consultants, or other parties in any industry in connection with legal matters.  The governmental entities or third parties involved with legal matters could be located in any country in which BF-EAC provides services, including but not limited to:  Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Malta, Netherlands, Spain, Sweden, United Kingdom, and U.S.  The purposes of these transfers are compliance with legal obligations and assertion of legal rights.

III. COOKIES & SIMILAR TECHNOLOGIES

As you interact with our Sites, we, with assistance from third-party analytics service providers, collect personal data pertaining to your use of our Sites and the devices and programs from which you access our Sites (“Usage Data”) using cookies and similar technologies.

    • What are cookies?
          • Cookies are small computer files sent or accessed from your browser on the hard drive of your computer, mobile device, or tablet that contain information about your computer, such as your user ID, user settings, browsing history, and activities conducted while browsing websites (g., pages viewed; navigation around a Site; and donations made).
          • Cookies are used to “remember” when your computer or devices access our Sites.
    • How do we use cookies?
          • Cookies are essential for the effective operation of our Sites, and help you to purchase services from and make donations to us.
          • The primary purposes for which cookies are used are: (1) For the effective operation of our Sites, especially in connection with Site navigation and online transactions and (2) To assist BF-EAC in detecting and preventing fraud.
      • How can you manage cookies?
          • If you do not want Usage Data collected through the use of cookies and similar technologies, there is a procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them. Be aware though that you may also lose some saved information (g., site preferences), some services and functionalities may not work properly at all (e.g., donations), and you may have to manually adjust some preferences every time you visit a site/page. Cookies that are required to enable core site functionality cannot be disabled.
          • To assist in controlling site-specific cookies, check the privacy and cookie settings in your preferred browser.

If you are in the European Union, or another country that requires your consent before processing your Usage Data, we process your Usage Data based on the consent you provide when you click the box noting that you “agree” to the processing of your personal data obtained through cookies and other data collection tools.  You may withdraw your consent by clicking the “Manage consent” button at the bottom of each page and moving the sliders in the Privacy overview to disabled.

Cookie Policy Details

Our Sites provide links to other third-party Internet websites as a service to you. We do not control and are not responsible for the privacy practices of such other third-party Internet websites. If you link to such a website through our Sites, you should always review any privacy notice that is available for that website. For example, AmazonSmile permits you to purchase goods from Amazon that will prompt Amazon to make donations to BF-EAC.  You may review AmazonSmile’s privacy notice at this link.

V. CHILDREN’S PRIVACY

Our Sites are not directed to individuals under the age of 18. No personal data should be submitted to our Sites directly by visitors under 18 years of age.  If we learn that we have collected personal data directly from someone under 18, we will take steps to delete the personal data as soon as possible.

VI. RETENTION OF PERSONAL DATA

BF-EAC will retain personal data for the time period necessary to meet our legal obligations and to fulfill the purposes for which such personal data was originally collected or received.  If you are a resident of the EU or any other country that provides data subjects with the right to delete, please see the section below under “Personal Data Rights” for information on the right to erasure.

VII. PROTECTING YOUR PERSONAL DATA

We implement technical and organizational measures designed to assist in maintaining the security and confidentiality of personal data; safeguarding against anticipated threats to the confidentiality, integrity, and availability of personal data; and protecting personal data against accidental or unlawful destruction, loss, alteration, and unauthorized access or disclosure.

However, whenever personal data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical and organizational measures that we have in place to protect your personal data, you should use appropriate security measures to protect your personal data. If you believe that any personal data you have provided to us is no longer secure, please notify us immediately at [email protected].

VIII. PERSONAL DATA RIGHTS

If you reside in the European Union or the United Kingdom (U.K.), you have the following rights, subject to the conditions set forth by applicable data protection law (i.e., the General Data Protection Regulation (GDPR) or the U.K. General Data Protection Regulation (U.K. GDPR)):

      • Right of Access. You have the right to receive a copy of the personal data that we hold about you.
      • Right to Rectification. You have the right to correct or complete any inaccurate or incomplete personal data that we hold about you.
      • Right to Deletion. In certain circumstances, you have the right to request that we erase the personal data that we hold about you.
      • Right of Data Portability. In certain circumstances, you have the right to request that we supply you with the personal data that we hold about you in a structured, commonly used and machine-readable format and/or, where technically feasible, to transmit such personal data to another organization.
      • Right to Restrict Processing. In certain circumstances, you have the right to restrict our processing of the personal data that we hold about you.
      • Right to Bring a Complaint to Supervisory Authority. You have the right to lodge a complaint with the relevant supervisory data protection authority.
      • Right to Withdraw Consent. If our lawful basis for processing your personal data is your consent, you have the right to withdraw your consent at any time.
      • Right to Object. You have the right to object to the processing of your personal data on certain grounds, including:
            • For Direct Marketing Purposes. The right to object to the processing of your personal data for direct marketing purposes, including profiling related to direct marketing.
            • For Legitimate Interests. The right to object to the processing of your personal data that is based on our or a third party’s legitimate interests, including profiling related to such legitimate interests.
            • For Public Interest or Exercise of Official Authority. The right to object to the processing of your personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Beteseb Felega – Ethiopian Adoption Connection, if any such processing is conducted.

Please see the Exercising Your Rights section of this Privacy Policy to learn how to exercise your rights.  For more information about your rights under the GDPR, including information about the circumstances under which different rights are applicable, please visit the European Commission’s My Rights Page, which can be viewed in a number of languages.

If you are located outside the European Union or the U.K., you may have privacy rights under your local laws.

IX. EXERCISING YOUR RIGHTS

To exercise your rights described in this Privacy Policy, please send an email to [email protected] including the following information:

      • Your name;
      • The country in which you currently reside, and if in the United States, the state in which you currently reside;
      • Which privacy right(s) you are exercising;
      • Details that will assist us in responding to your request, including:
          • If you are exercising access rights, the information to which you are requesting access;
          • If you are exercising deletion rights, the information for which you are requesting deletion;
          • Any other relevant information about your personal data and/or the right you are exercising; and
          • A phone number and/or email address at which we can reach you.
X. CROSS-BORDER TRANSFERS OF PERSONAL DATA

When you use our Sites or we otherwise receive your personal data, your personal data may be stored on servers in the United States and/ or in other countries outside of the European Union/European Economic Area (“EU/EEA”).  Your personal data may be transferred to and processed by BF-EAC and its third-party service providers, in the United States or in other countries outside of the EU/EEA. The data protection and privacy laws of the United States and other countries may not be as comprehensive as the laws of your country.  For example, personal data transferred to the United States may be subject to lawful access requests by U.S. federal and state authorities.  For transfers of UK and EU/EEA personal data to service providers in the United States and other locations outside of the UK and EU/EEA for which no adequacy decision has been reached by appropriate regulatory authorities, BF-EAC will rely on Standard Contractual Clauses as the lawful transfer mechanism to support such transfers.

XI. DATA CONTROLLER

Personal data that is collected directly from individuals and used by BF-EAC for its mission purposes, as well as personal data collected by BF-EAC through our Sites, is controlled by BF-EAC, which is headquartered at Beteseb Felega – Ethiopian Adoption Connection BF-EAC, PO Box 860046, Shawnee, Kansas 66226, and which you can contact by email at [email protected]

XII. DO NOT TRACK

We do not track our Site users over time and across third-party websites and online services (e.g., mobile apps), and therefore we do not respond to Do Not Track signals.  However, third parties may collect information relating to your online activities over time and across different sites and apps when you use our Site in order to provide you with content that is likely to be of interest to you.

XIII. PRIVACY POLICY UPDATES

We may update this Privacy Policy from time to time as we add new services or offerings; as we improve our current services and offerings; and as technologies and laws change. It is our policy to post any changes we make to our Privacy Policy on our Sites. Any changes will become effective thirty (30) days after our posting of the revised Privacy Policy on the Sites. The date this Privacy Policy became effective is identified at the top of the policy. If we make material changes to how we treat the personal data that falls within the scope of this Privacy Policy, we will notify you by email or through a prominent notice on the homepage of our Site.

XIV. HOW TO CONTACT US

If you have any questions about this privacy policy or our privacy practices, any privacy complaints, or any need for assistance relating to your personal data, you may contact us via email at [email protected], or by writing to us at the following address:

Beteseb Felega – Ethiopian Adoption Connection BF-EAC

PO Box 860046

Shawnee, Kansas 66286-0046