Beteseb Felega – Ethiopian Adoption Connection

Adoption Reunion Services Privacy Policy

Effective Date: [Jan 29, 2023]
Last Updated: [Jan 29, 2023]

Your privacy is important to Beteseb Felega – Ethiopian Adoption Connection, Inc. and its volunteers and social workers, (collectively 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 use our database and our other services (collectively “Service” or “Services”) or when you join the DNA Group Project we administer.

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

“You” and “your” refers to any person reading this Privacy Policy who has received BF-EAC Services or who has joined the DNA Group Project that BF-EAC administers.

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

Website Privacy Practices  This policy does not address our Personal Data collection, usage, and transfer practices in connection with our Sites, volunteers, or employees, or our data protection and privacy practices for processing such data.  To learn about our data collection, usage, and transfer practices and data protection and privacy practices in connection with our Sites, including cookies and donations, please refer to our Beteseb Felega – Ethiopian Adoption Connection Website Privacy Policy

To jump to a specific section of this Privacy Policy, please click on a link below:

 I. CATEGORIES OF PERSONAL DATA WE PROCESS

We will process the following categories of personal data when you use our Services or join the DNA Group Project that we administer:

      • Personal Data that is Processed when You Submit Information for the Family Search Database. When you submit information for the Family Search Database, we collect your personal data including your name, email address, phone number, prior use of search services, role (i.e., adoptee, adoptive parent, or other), and majority (i.e., fact that you are over 18 years old).

Purpose and Legal Ground:

We process this personal data to (1) provide you with the Family Search Database services you request, and (2) to prevent the misuse or fraudulent use of the Family Search Database.  The legal ground for processing your personal data for this purpose is our legitimate interest in (1) accomplishing our mission to provide adoption reunion services to families separated by adoption; and (2) protecting BF-EAC and the community we serve from the misuse or fraudulent use of our services.

      • Personal Data that is Processed when an Adoptee, Adoptive Parent, or Ethiopian Family Member Provides Adoption Information for the Family Search Database. When you, your adopted child, your adoptive parents, your Ethiopian family member, your child’s Ethiopian family member, your adoptive relative, or your adoptive relative’s parent provides adoption information for the Family Search Database, we will collect your personal data.
      • Adoptee Personal Data. If you are the relevant adoptee, we will collect your gender, year of birth, name at adoption, Ethiopian birth name, age at adoption, year of adoption, Ethiopian relative’s names, interest in finding siblings, biometric identifiers (g., scars, birthmarks, surgeries and other unique traits), age of entry to care center, year of entry to the same, care center’s name, care center’s region, care center’s zone, care center’s city, adoption agency’s name, adoptive country, adoption agency’s partner adoption agencies, images of you, images of your adoptive family, images of your Ethiopian family, and other personal data provided by you, your adoptive parents, or your Ethiopian family member.

Purpose and Legal Ground:

We process this personal data to (1) connect you and your adoptive family with your Ethiopian family using the Family Search Database; and (2) provide additional adoption reunion services such as Paid Search Services, Family Visit and Letter Delivery, or Phone Call Check-in services when requested by you or by your adoptive parents, if you are a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adoptive family, and your Ethiopian family as you reconnect.  Your biometric identifiers (e.g., scars, birthmarks, surgeries and other unique traits) are a special category of personal data. The additional legal ground for processing this special category of personal data for this purpose is your explicit consent, which you may withdraw at any time by emailing us at [email protected].  Please see the Exercising Your Rights section of this Privacy Policy to learn more about how to exercise your rights.

      • Adoptive Parent Personal Data. If you are an adoptive parent, we will collect your country of residence, interest in finding your adopted child’s siblings, images of you, images of your adopted child, and other personal data about you provided by you, your adopted child, or your adopted child’s Ethiopian family.

Purpose and Legal Ground:

We process this personal data to (1) connect you and your adopted child with your child’s Ethiopian family using the Family Search Database; and (2) provide additional adoption reunion services such as Paid Search Services, Family Visit and Letter Delivery, or Phone Call Check-in services when requested by your adopted child or by you, if your child is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adopted child, and your child’s Ethiopian family as they reconnect.

      • Ethiopian Family Member Personal Data. If you are an Ethiopian family member, we will collect your name, your location in Ethiopia, your biometric identifiers (e.g. scars, birthmarks, surgeries and other unique traits), images of you, images of your adopted relative, your living conditions, you education level, your health status, your economic situation, your contact information, your social media accounts, video and audio recordings of you, and other personal data about you provided by you, your adopted relative, or your adopted relative’s parent.

Purpose and Legal Ground:

We process this personal data to (1) connect you with your adopted relative using the Family Search Database; and (2) provide additional adoption reunion services such as Family Visit and Letter Delivery or Phone Call Check-in services, when requested by your adopted relative or that relative’s adoptive family, if your adopted relative is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adopted relative, and your adopted relative’s adoptive family as you reconnect.  Your biometric identifiers (e.g. scars, birthmarks, surgeries and other unique traits) are a special category of personal data; the additional legal ground for processing this special category of personal data for this purpose is your explicit consent, which you may withdraw at any time by talking with our social worker who helped you to provide your information for the Family Search Database or by emailing us at [email protected].  Please see the Exercising Your Rights section of this Privacy Policy to learn more about how to exercise your rights.

      • Personal Data that is Processed when You Submit Information for Paid Adoption Reunion Services. When you submit information for paid adoption reunion services, which include (1) Paid Search Services, (2) Family Visit and Letter Delivery, (3) Phone Call Check-in, and (4) Translation Services, we collect your personal data including your name, email address, phone number, role (e., adoptee or adoptive parent), and majority (i.e., fact you are over 18 years old).

Purpose and Legal Ground:

We process this personal data to (1) provide you with the paid adoption reunion services you request; and (2) prevent misuse or fraudulent use of the paid adoption reunion services.  The legal ground for processing your personal data for this purpose is our legitimate interest in (1) accomplishing our mission to provide adoption reunion services to families separated by adoption; and (2) protecting BF-EAC and the community we serve from the misuse or fraudulent use of our services.

      • Personal Data that is Processed when an Adoptee or Adoptive Parent Requests Paid Search Services. When you, your adopted parent, your adopted child, your adoptive relative, or your adoptive relative’s parent requests Paid Search Services (i.e., requests that we send one of our social workers to perform a foot search for you, your Ethiopian family, or your adopted child’s Ethiopian family), we will collect your personal data.
      • Adoptee Personal Data. If you are the relevant adoptee, we will collect your Ethiopian name, an image of you and your adoptive family, four or five images of you at different ages, a list of organizations that cared for you or facilitated your adoption, a list of people in Ethiopia who may have information about you or your Ethiopian family, a list of places in Ethiopia where there may be information about you or your family (i.e., police stations and offices where you would like us to request your personal data), a chronological summary of your history in Ethiopia, your goals for the Paid Search Services, your personal data found in the adoption documents, and your other personal data provided by you or your adoptive parent, if you are a minor.

Purpose and Legal Ground:

We process this personal data to (1) perform a search on foot in Ethiopia for your Ethiopian family; (2) provide a report on the search activities; and (3) provide additional adoption reunion services such as Family Visit and Letter Delivery or Phone Call Check-in services when requested by you or by your adoptive parents, if you are a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adoptive family, and your Ethiopian family as you reconnect.

      • Adoptive Parent Personal Data. If you are an adoptive parent, we will collect an image of you and your adopted child, a chronological summary of your child’s history in Ethiopia, your goals for the Paid Search Services, your personal data found in the adoption documents, and your other personal data provided by your adopted child or by you, if your child is a minor.

Purpose and Legal Ground:

We process this personal data to (1) perform a search on foot in Ethiopia for your adopted child’s Ethiopian family; (2) provide a report on the foot search; and (3) provide additional adoption reunion services such as Family Visit and Letter Delivery or Phone Call Check-in services when requested by your adopted child or by you, if your adopted child is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adopted child, and your child’s Ethiopian family as they reconnect.

      • Ethiopian Family Member Personal Data. If you are an Ethiopian family member, we will collect a list of people in Ethiopia who may have information about you, a list of places in Ethiopia where there may be information about you, your living conditions, your education level, your current health status, your job, your economic situation, your contact information, your social media accounts, videos of you, and your other personal data provided by you, (usually just information regarding your location or contact information), your family, your adopted relative, or your adopted relative’s parent, if your relative is a minor.

Purpose and Legal Ground:

We process this personal data to (1) perform a search on foot in Ethiopia for you and your family; (2) draft a report on the foot search; and (3) provide additional adoption reunion services such as Family Visit and Letter Delivery or Phone Call Check-in services when requested by your adopted relative or that relative’s adoptive family, if your adopted relative is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support your adopted relative’s adoptive family, you, and your adopted relative as you reconnect.

      • Personal Data that is Processed when an Adoptee or Adoptive Parent Registers for a Family Visit and Letter Delivery. When you, your adopted parent, your adopted child, your adopted relative, or your adopted relative’s parent registers for a family visit and letter delivery (e., register to have us visit and deliver a letter to your Ethiopian family or to your adopted child’s Ethiopian family), we will collect your personal data.
      • Adoptee Personal Data. If you are the relevant adoptee, we will collect your age, your grade in school, your hobbies, your family member names, your family member ages, your general location information, images of you, images of you with your family and home, your personal data included in the letter to your Ethiopian family, your personal data included in the letter delivery information, and your other personal data provided by you or your adoptive parent, if you are a minor.

Purpose and Legal Ground:

We process this personal data to (1) personally deliver a letter to your Ethiopian family; (2) provide a photo verifying the letter was received; (3) provide a social report on your Ethiopian family; and (4) provide additional adoption reunion services such as additional Family Visit and Letter Delivery or Phone Call Check-in services when requested by you or by your adoptive parents, if you are a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adoptive family, and your Ethiopian family as you reconnect.

      • Adoptive Parent Personal Data. If you are an adoptive parent, we will collect your name, your family member names, your family member ages, your general location information, images of you with your family and home, personal data included in the letter to your adopted child’s Ethiopian family, personal data included in the letter delivery information, and your other personal data provided by your adopted child or by you, if your child is a minor.

Purpose and Legal Ground:

We process this personal data to (1) personally deliver a letter to your adopted child’s Ethiopian family; (2) provide a photo verifying the letter was received; (3) provide a social report on your adopted child’s Ethiopian family; and (4) provide additional adoption reunion services such as additional Family Visit and Letter Delivery or Phone Call Check-in services when requested by your adopted child or by you, if your adopted child is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adopted child, and your child’s Ethiopian family as they reconnect.

      • Ethiopian Family Member Personal Data. If you are an Ethiopian family member, we will collect images of you, images of your family, your living conditions, your education level, your current health status, your job, your economic situation, a short video of you and your family, and other personal data provide by you, your family, your adopted relative, or your relative’s adoptive parent, if your relative is a minor.

Purpose and Legal Ground:

We process this personal data to (1) personally deliver a letter and any pictures that come with it to you and your family; (2) provide a photo verifying the letter was received; (3) provide a social report on your family; and (4) provide additional adoption reunion services such as additional Family Visit and Letter Delivery or Phone Call Check-in services when requested by your adopted relative or that relative’s adoptive parents, if your adopted relative is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support your adopted relative’s parent, your adopted relative, and you as you reconnect.

      • Personal Data that is Processed when an Adoptee or Adoptive Parent Registers for a Phone Call Check-in. When you, your adopted parent, your adopted child, your adopted relative, or your adopted relative’s parent registers for a phone call check-in (e., register to have us make a phone call check-in with your Ethiopian family or with your adopted child’s Ethiopian family), we will collect your personal data.
      • Adoptee Personal Data. If you are the relevant adoptee, we will collect your age, your grade in school, your hobbies, your family member names, your family member ages, your general location information, images of you, images of you with your family and home, your personal data included in the questions asked during the call, your personal data included in the contact information for your Ethiopian family, and your other personal data provided by you or your adoptive parent, if you are a minor.

Purpose and Legal Ground:

We process this personal data to (1) make a phone call check-in with your Ethiopian family; (2) provide a report detailing the call with your Ethiopian family; (3) provide your Ethiopian family with pictures of you and your adopted family; and (4) provide additional adoption reunion services such as additional Phone Call Check-in or Family Visit and Letter Delivery services when requested by you or by your adoptive parents, if you are a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adoptive family, and your Ethiopian family as you reconnect.

      • Adoptive Parent Personal Data. If you are an adoptive parent, we will collect your name, your family member names, your family member ages, your general location information, images of you with your family and home, your personal data included in the questions asked during the call, your personal data included in the contact information for your Ethiopian family, and your other personal data provided by your adopted child or by you, if your child is a minor.

Purpose and Legal Ground:

We process this personal data to (1) make a Phone Call Check-in with your adopted child’s Ethiopian family; (2) provide a report detailing the call with your adopted child’s Ethiopian family; (3) provide your adopted child’s Ethiopian family with pictures of you and your family; and (4) provide additional adoption reunion services such as additional Phone Call Check-ins or Family Visit and Letter Delivery services when requested by your adopted child or by you, if your adopted child is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adopted child, and your child’s Ethiopian family as they reconnect.

      • Ethiopian Family Member Personal Data. If you are an Ethiopian family member, we will collect personal data needed to make a report detailing our Phone Call Check-In, you’re your other personal data provide by you, your adopted relative or your relative’s adoptive parent, if your relative is a minor.

Purpose and Legal Ground:

We process this personal data to (1) make a Phone Call Check-In with you and your family, (2) send you images from your adopted relative, (3) provide a report detailing the call to your adopted relative and your relative’s adoptive family, (4) provide you with pictures of your adoptive relative and your relative’s adoptive family, and (5) provide additional adoption reunion services such as additional Phone Call Check-ins or Family Visit and Letter Delivery services when requested by your adopted relative or that relative’s adoptive family, if your adopted relative is a minor.  The legal ground for processing this personal data for this purpose is our legitimate interest in pursuing our mission to support you, your adopted relative, and your adopted relative’s adoptive family as you reconnect.

      • Personal Data that is Processed when an Adoptee or Adoptive Parent Registers for Translation Services. When you, your adoptive parent, your adopted child, your adopted relative, or your adoptive relative’s parent registers for translation services, we will collect the personal data included in the documents and videos submitted to us for translation.

Purpose and Legal Ground:

We process this personal data to (1) translate the documents and videos; and (2) provide additional adoption reunion services such as Paid Search Services, Family Visit and Letter Delivery, or Phone Call Check-in services when requested by you, your adopted child, your adoptive parents, your adoptive relative, or your adoptive relative’s parents, if your relative is a minor.  The legal ground for processing this personal data for these purposes is our legitimate interest in pursuing our mission to support adoptees, their adoptive parents, and their Ethiopian families as they reconnect.

      • What is Processed when You Apply for an Ethiopian Adoptee Search Scholarship. When you apply for an Ethiopian adoptee search scholarship for our paid adoption reunion services, we will collect your personal data including your name, address, phone number, marital status, net income and worth, spouse net income and worth, extenuating circumstances, number of dependents, and independence from parents (e., whether you are living with your adoptive parents) from you.

Purpose and Legal Ground:

We process this personal data to (1) evaluate your need for reduced fee adoption reunion services; and (2) provide you with adoption reunion services at a reduced fee by grouping your search services with other adoptees who could not otherwise afford our adoption reunion services or with other paid services.  The legal ground for processing this personal data for this purpose is our legitimate interest in supporting you as you reconnect with your Ethiopian family.

      • Personal Data that is Processed when You Make a Payment. When you make a payment for paid adoption reunion services, which include Paid Search Services; Family Visit and Letter Delivery; Phone Call Check-in, and Translation Services, we will collect your personal data including your name, email address, services purchased, and payment amount from you. If you make a payment with a credit card, your credit card information will be processed by one of our payment processors, which include PayPal, Stripe, and Zelle.

Purpose and Legal Ground:

We process this personal data to document your payment for services, and to provide you with a receipt for your payment.  The legal ground for our processing of this personal data for that purpose is performance of a contract.  We also process this personal data to prevent fraudulent transactions.  The legal ground for our processing of this personal data for that purpose is our legitimate interest in protecting BF-EAC and the community we serve from attempts to engage in fraudulent transactions.

      • Personal Data that is Processed when You Join the DNA Group Project that We Administer. If you join a DNA Group Project that we administer, we will receive access to your account name, myFTDNA pages, kit number, earliest known ancestors, surnames, and genetic data including your mtDNA haplogroup origins, Y-DNA haplotree and SNPs, individual autosomal markers, and matches.

Purpose and Legal Ground:

We consult your account name, myFTDNA pages, and kit number to (1) evaluate your request to join the DNA Group Project that we administer; and (2) provide you with the opportunity to connect with your family through the DNA Group Project that we administer.  The legal ground for our processing of your account name, myFTDNA pages, and kit number is our legitimate interest in (1) providing adoptees and Ethiopian families with an opportunity to reconnect; and (2) protecting the Group Project we administer from misuse and fraudulent use.  Your genetic data is a special category of personal data. We will only consult your genetic data, if you have given us that access, when you match with a DNA kit that we administer that is a member of the DNA Group Project that we administer to determine whether the match merits reaching out to the individual on whose behalf we administer the kit.  The legal ground for our limited processing of your genetic data is your explicit consent, which you may withdraw by withdrawing your participation from the DNA Group Project that we administer.  We will not consult or further process your genetic data for any other purposes.

      • Personal Data that is Processed when We Administer Your DNA Kit on Your Behalf. If you are an Ethiopian family member and request that we administer your DNA kit due to language barriers, limited internet access, or any other reason, we will consult the personal data on your myFTDNA account, including your first name, kit number, account name, and genetic data, such as autosomal DNA results, Y-DNA results, haplo group, ancestral origins, and DNA matches, with information on shared DNA segments in centimorgans.

Purpose and Legal Ground:

We will consult the personal data, including your genetic data, on your myFTDNA account to provide you with updates on your genetic matches.  The legal grounds for processing this personal data for this purpose is your explicit consent, which you may withdraw at any time by talking with our Ethiopian social worker who is helping with your kit.  When requested, we will briefly download your genetic data and transfer it to GEDmatch and other commercial databases such as My Heritage and Ancestry, before deleting it from our systems, to enable you to connect with others through those databases.  The legal grounds for processing this personal data for this purpose is your explicit consent, which you may withdraw at any time by talking with our Ethiopian social worker who is helping to administer your kit.  We will not store, modify, use, or otherwise process your genetic data for additional purposes.
 

 II. RECIPIENTS OF PERSONAL DATA

In connection with the purposes set forth in this Privacy Policy, we may share your personal data with one or more of the following categories of third-party recipients:

      • Individuals Browsing the Internet. If you, your adopted child, your adoptive parents, your Ethiopian family member, or your child’s Ethiopian family member provide adoption information for the Family Search Database, we will make your personal data available to individuals browsing the internet.  These individuals could work in any public or private organization, or individually, in any industry, and could be located anywhere in the world.  The purpose of this disclosure is to provide Family Search Database services to help adoptees and Ethiopian families as they reconnect.
          • Adoptee Personal Data. If you are an adoptee, we will make your year of birth, gender, Ethiopian birth name, care center’s name, care center’s region, and country of adoption available to individuals searching the internet.
          • Adoptive Parent Personal Data. If you are an adoptive parent, we will make your country of adoption available to individuals searching the internet.
          • Ethiopian Family Member Personal Data. If you are Ethiopian family member, we will make the fact that you are searching for your adopted relative available to individuals searching the internet.
      • Family Search Database Visitors. If you, your adopted child, your adoptive parents, your Ethiopian family member, or your child’s Ethiopian family member provide adoption information for the Family Search Database, we will make your personal data available to Family Search Database visitors.  The Family Search Database visitors could work in any public or private organization, or individually, in any industry, and could be located anywhere in the world.  The purpose of this disclosure is to provide Family Search Database services to help adoptees and Ethiopian families as they reconnect.
          • Adoptee Personal Data. If you are an adoptee, we will make your gender, year of birth, Ethiopian birth name, age at adoption, year of adoption, Ethiopian relative’s names, biometric identifiers (e.g., scars, birthmarks, surgeries and other unique traits), age of entry to care center, year of entry to the same, care center’s name, care center’s region, care center’s zone, care center’s city, adoption agency’s name, adoptive country, adoption agency’s partner adoption agencies, images of you, and images of your Ethiopian family available to Family Search Database visitors.
          • Adoptive Parent Personal Data. If you are an adoptive parent, we will make your country of adoption available to Family Search Database visitors.
          • Ethiopian Family Member Personal Data. If you are an Ethiopian relative, we will make your first name and last initial, family member’s first names, region and zone of relinquishment/abandonment, and your general location available to Family Search Database visitors.
      • Social Media Service Provider.  If you, your adopted child, your adoptive parents, your Ethiopian family member, or your child’s Ethiopian family member provide adoption information for the Family Search Database, we will make your personal data available to the Social Media Service Provider, by posting entries from our Family Search Data base to our Facebook page.  The purpose of this disclosure is to provide an additional connection point for Family Search Database services.
          • Adoptee Personal Data. If you are an adoptee, we disclose your gender, year of birth, Ethiopian birth name, age at adoption, year of adoption, Ethiopian relative’s names, biometric identifiers (e.g., scars, birthmarks, surgeries and other unique traits), age of entry to care center, year of entry to the same, care center’s name, care center’s region, care center’s zone, care center’s city, adoption agency’s name, adoptive country, adoption agency’s partner adoption agencies, images of you, and images of your Ethiopian family to Facebook.
          • Adoptive Parent Personal Data. If you are an adoptive parent, we disclose your country of adoption to Facebook.
          • Ethiopian Family Member Personal Data. If you are an Ethiopian relative, we disclose your first name and last initial, family member’s first names, region and zone of relinquishment, and your location to Facebook.
      • Facebook Users. If you, your adopted child, your adoptive parents, your Ethiopian family member, or your child’s Ethiopian family member provide adoption information for the Family Search Database, we will make your personal data available to Facebook users by posting entries from our Family Search Data base to our Facebook page.  Facebook users could work in any public or private organization, or individually, in any industry, and could be located anywhere in the world.  The purpose of this disclosure is to provide an additional connection point for Family Search Database services.
          • Adoptee Personal Data. If you are an adoptee, we disclose your gender, year of birth, Ethiopian birth name, age at adoption, year of adoption, Ethiopian relative’s names, biometric identifiers (e.g., scars, birthmarks, surgeries and other unique traits), age of entry to care center, year of entry to the same, care center’s name, care center’s region, care center’s zone, care center’s city, adoption agency’s name, adoptive country, adoption agency’s partner adoption agencies, images of you, and images of your Ethiopian family to Facebook users.
          • Adoptive Parent Personal Data. If you are an adoptive parent, we disclose your country of adoption to Facebook users.
          • Ethiopian Family Member Personal Data. If you are an Ethiopian relative, we disclose your first name and last initial, family member’s first names, region and zone of relinquishment, and your general location to Facebook users.
      • Adoptees If you are an adoptee and request that we transfer your personal data to your adoptive parent, we will transfer your personal data to your adoptive parents.  If you are an Ethiopian family member seeking to reconnect with your adopted relative, we will transfer your personal data to your adopted relative.  Your adopted child or adopted relative could work in any public or private organization, or individually, in any industry, and could be located anywhere around the world, but your adopted child or adopted relative will likely be located in one of the countries that we serve, including Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Malta, Netherlands, Spain, Sweden, U.K., and U.S.  The purpose of this transfer is to provide your adopted child or adopted relative with requested support and additional adoption reunion services.
          • Adoptive Parent Personal Data. If you are an adoptive parent, we will transfer your name, your family member names, your family member ages, your general location information, country of residence, goals for Paid Search Services, images of you, images of you with your adopted child, images of you with your family and home, and your other personal data that we may have in delivered letters, call questions, adoption documents, and translated documents and videos to your adopted child.
          • Ethiopian Family Member Personal Data. If you are an Ethiopian family member, we will transfer a list of people in Ethiopia who may have information about you, a list of places in Ethiopia where there may be information about you, your living conditions, your education level, your current health status, your job, your economic situation, your contact information, your social media accounts, videos of you and your family, images of you, images of your family, and your other personal data that we may have in paid search reports, family visit reports, call check-in reports, adoption documents, and translated documents and videos to your adopted relative.
      • Adoptive Parents. If you are an adoptive parent and request that we transfer your personal data to your adopted child or your adopted child reaches majority and requests the same, we will transfer your personal data to your adopted child. If you are an Ethiopian family member seeking to reconnect with your adopted relative, we will transfer your personal data to your adopted relative’s parents if your adoptive relative is a minor.  We also will transfer your personal data to your adopted relative’s adoptive parents if adoptive relative is not a minor, but requests such a transfer.  Your adoptive parents or adopted relative’s parents could work in any public or private organization, or individually, in any industry,  and could be located anywhere around the world, but your adoptive parent or adopted relative’s parents will likely be located in one of the countries that we serve, including Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Malta, Netherlands, Spain, Sweden, U.K., and U.S.  The purpose of this transfer is to provide your adoptive parent or adoptive relative’s parents with the personal data requested.
          • Adoptee Personal Data. If you are an adoptee and request that we share your personal data with your adoptive parents, we will transfer your age, your grade in school, your hobbies, your family member names, your family member ages, your general location information, your Ethiopian name, images of you at different ages, images of you with your family and home, a list of organizations that cared for you or facilitated your adoption, a list of people in Ethiopia who may have information about you or your Ethiopian family, a list of places in Ethiopia where there may be information about you or your Ethiopian family, a chronological summary of your history in Ethiopia, your goals for Paid Search Services, and your other personal data that we may have in delivered letters, call questions, adoption documents, and translated documents to your adoptive parents if requested.
          • Ethiopian Family Member Personal Data. If you are an Ethiopian family member, we will transfer a list of people in Ethiopia who may have information about you, a list of places in Ethiopia where there may be information about you, your living conditions, your education level, your current health status, your job, your economic situation, your contact information, your social media accounts, videos of you and your family, images of you, images of your family, and your other personal data that we may have in paid search reports, family visit reports, check-in reports, adoption documents, and translated documents and videos to your adoptive relative’s parents.
      • Ethiopian Family. If you request that we deliver your personal data or your family’s personal data to your Ethiopian family or your adopted child’s Ethiopian family, we will transfer the personal data you have requested delivered to them.  Your Ethiopian family members or your adopted child’s Ethiopian family members could work in any public or private organization, or individually, in any industry.  Your Ethiopian family members will be located in Ethiopia.  The purpose of this transfer is to provide you, your adoptive parents, and your adopted child with requested adoption reunion services, such as Family Visit and Letter Delivery and Phone Call Check-in services.
          • Adoptee Personal Data. If you are an adoptee, at your request, or if you are a minor, at your adoptive parent’s request, we will transfer your age, your grade in school, your hobbies, your family member names, your family member ages, your general location information, images of you, images of you with your family and home, and your other personal data included in your family letter or call check-in questions to your Ethiopian family.
          • Adoptive Parent Personal Data. If you are an adoptive parent, at your adopted child’s request or your request, if your adopted child is a minor, we will transfer your name, your family member names, your family member ages, your general location information, images of you with your family and home, and your other personal data included in your family letter or call check-in questions to your adopted child’s Ethiopian family.
      • Our Social Workers. If you, your adopted child, or your adoptive parents request paid adoption reunion services such as Paid Search Services, Family Visit and Letter Delivery, Phone Call Check-in, or Translation services, we will transfer personal data to our social workers.  Our social workers will be a part of the human health and social work industry, the social work sector, and the adoption activities subsector.  Our social workers are located in Ethiopia.  The purpose of this transfer is to provide you, your adoptive parents, and your adopted child with requested adoption reunion services.
          • Adoptee Personal Data. If you are an adoptee, we will transfer your Ethiopian name, images of you at different ages, images of you with your family and home, a list of organizations that cared for you or facilitated your adoption, a list of people in Ethiopia who may have information about you or your Ethiopian family, a list of places in Ethiopia where there may be information about you or your Ethiopian family, a chronological summary of your history in Ethiopia, your goals for Paid Search Services, and your other personal data that we may have in delivered letters, call check-in questions, adoption documents, and translated documents to our social workers.
          • Adoptive Parent Personal Data. If you are an adoptive parent, we will transfer your country of residence, goals for Paid Search Services, images of you, images of you with your adopted child, and your other personal data that we may have in delivered letters, call questions, adoption documents, and translated documents and videos to our social workers.
          • Ethiopian Family Member’s Personal Data. If you are Ethiopian family member, your personal data will often be collected by our social workers.  However, when your adopted relative requests paid adoption reunion services from us, we will transfer a list of people in Ethiopia who may have information about you, a list of places in Ethiopia where there may be information about you, and your other personal data that we may have in paid search reports, family visit reports, call check-in reports, adoption documents, and translated documents and videos to our social workers.
      • Electronic Payment Processors. If you make a payment to BF-EAC, we will transfer your personal data, specifically your name, services purchased, and payment amount to The purpose of this transfer is to (1) enable us to receive and process your payment 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, Venmo, or Zelle.
      • DNA Group Project Members. If you join the DNA Group Project that we administer, the Group Project will automatically disclose your personal data, including your kit number and anonymized DNA test results, to Group Project admins in accordance with your project preferences page on my FTDNA.  Before joining the group project, you should review your project preferences and ensure that (1) you are comfortable joining the Group Project; and (2) you agree with providing your anonymized DNA test results and other personal data to Group Project members and to BF-EAC as the Group Project Administrator.  The DNA Group Project members could work in public or private organization, or individually, in any industry, and could be located anywhere in the world.  The purpose of this disclosure is to provide you and other Group Project members with an opportunity to connect with your families.
      • Genealogy Search Service Providers. If we administer your kit, on your request we will transfer your kit number, account name, and genetic data, such as autosomal DNA results, Y-DNA results, haplo group, ancestral origins, and DNA matches, with information on shared DNA segments in centimorgans to GEDmatch and other commercial DNA databases such as My Heritage and Ancestry. The purpose of this transfer is to provide you with another opportunity to connect with your family.
      • 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) is required to 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 or third party.

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, U.K., and U.S.  The purposes of these transfers are compliance with legal obligations and assertion of legal rights.

III. THIRD PARTY PRIVACY PRACTICES

Our Sites provide links to other third-party Internet websites as a service to you. We 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, BF-EAC encourages searching adoptive parents, adoptees, and Ethiopian families to make use of DNA testing services and data bases, such as Family Tree DNA and GEDmatch. You may use the following links to review Family Tree DNA’s privacy statement and Group Project participation informed consent and GEDmatch’s terms of service and privacy policy. 

 II. CHILDREN’S PRIVACY

Our Services are not directed to individuals under the age of 18, and we do not collect and process data submitted directly to our site by individuals under the age of 18 for our own purposes. No personal data should be submitted to our Services directly by any 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 such personal data as soon as possible.

V. RETENTION OF PERSONAL DATA

BF-EAC will retain personal data for the time period necessary to meet our legal obligations, for a time period necessary to fulfill the purposes for which such personal data was originally collected or received (e.g., as long as necessary to establish a connection between adoptive and biological families and to enable individuals to access and to review their search information) and to research and improve our efforts to accomplish those purposes, or until a user submits a request to delete personal data in accordance with an applicable law).

When BF-EAC acts as a kit administrator, we may store your genetic data on our servers for a short period of time while we upload your genetic data to a genetic data base. Your genetic data will be promptly deleted afterwards.

If you are a member of the DNA Group Project we administer, then we may consult your genetic data to connect you and your family.  However, we will not store your genetic data in any of our systems, unless we are administering your kit and then only for as long as needed to transfer it to a genealogy search service provider.

If you are a resident of the European Union 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.

VI. PROTECTING YOUR PERSONAL DATA

We implement technical and organizational measures that are 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].

VII. PERSONAL DATA RIGHTS

If you reside in the European Union or the 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.

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 that you may seek to exercise under your local laws.

VIII. EXERCISING YOUR RIGHTS

To exercise your privacy rights, please send an email to [email protected] including the following information:

        • Your name;
        • The country in which you currently reside, and if in the U.S., 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 Services, access our Sites, or we otherwise receive your personal data, your personal data may be stored on servers in the U.S. 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 provider (e.g., we may transfer adoption information to one of our Ethiopian social workers to conduct a foot search, our payment processor may transfer your payment information to a data center in another country), in the U.S. or in other countries outside of the EU/EEA. The data protection and privacy laws of the U.S. and other countries may not be as comprehensive as the laws of your country.  For example, personal data transferred to the U.S. 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 U.S. 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.

X. 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 in connection with our Services, 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 [email protected].

XI. DO NOT TRACK

We do not track our users of our Services 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 Services in order to provide you with content that is likely to be of interest to you.

X.PRIVACY POLICY UPDATES

We may update this Privacy Policy from time to time as we add new Services; as we improve our current Services; 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.

 X.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
P.O. Box 860046
Shawnee, Kansas 66286-0046