This privacy policy notice refers to www.circlemena.org and its purpose is to explain to you how we control, process, handle and protect your personal information while browsing or using this website, including your rights under current laws and regulations.

If you do not agree to the following policy you may wish to cease viewing / using this website.

Policy key definitions:

• I', 'our', 'us', or 'we', refers to the Circle, a partnership between Philanthropy Age and Pearl Initiative.
• 'You' or 'the user' refers to the person(s) using this website.
• GDPR means General Data Protection Act.
• PECR means Privacy and Electronic Communications Regulation.
• ICO means Information Commissioner's Office.
• Cookies mean small files stored on a user’s computer or device.

Processing of your personal data

Under the GDPR (General Data Protection Regulation) we control and/or process any personal information about you electronically using the following lawful bases.

We are exempt from registration in the ICO Data Protection Register because we operate as a nonprofit organisation.

Lawful basis: consent

We would like to send you notifications but we would never do this without your consent. 

We process your information in the following ways. We store your details so you are able to log in to our resources; and we retain your email address so we can send you notifications, provided that you have agreed to that.

We will continue to process your information on this basis until you withdraw consent or it is determined your consent no longer exists.

We do not share your information with third parties.

Your individual rights

Under the GDPR your rights are as outlined below. You can read more about your rights in details here. 

We handle subject access requests in accordance with the GDPR.

Transparent privacy explanations

We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.

Email marketing messages and subscription

Under the GDPR, we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the 'processing of your personal data' above.

Any email marketing messages we send are done so through an EMS, or email marketing service provider. An EMS is a third-party service provider of software/applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons/tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as times, dates, I.P addresses, opens, clicks, forwards, and geographic and demographic data.

Such data, within its limitations, will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or to manage your preferences/the information we hold about you at any time.

You can see any marketing messages for instructions on how to unsubscribe or manage your preferences, or otherwise contact the EMS provider.

Our EMS provider is Campaign Monitor. We hold the following information about you within our EMS system:

• Email address
• I.P address
• Subscription time and date.