Privacy Policy

A21 IS COMMITTED TO PROTECTING THE RIGHTS AND FREEDOMS OF DATA SUBJECTS AND SAFELY AND SECURELY PROCESSING YOUR DATA IN ACCORDANCE WITH ALL OF OUR LEGAL OBLIGATIONS

01 WHO WE ARE AND WHERE WE PROCESS DATA

A21 is a global organization, with legal entities, business processes, management structures, and technical systems that operate in many different countries and cross international borders. This Privacy Policy applies to all websites and domains owned or operated by A21 and entities owned, controlled by or affiliated with A21. Please note that any privacy statement posted on an A21 website specific to an A21 program or service will apply in addition to this Privacy Policy and in the event of any conflict shall prevail

The primary A21 website is hosted in the USA. However, all data is processed or stored on servers located in the USA, UK or Australia. By completing and submitting your data and communication preferences to A21 on a website or otherwise you are consenting to your data being held and/or processed in those countries by The A21 Campaign Limited, a company registered with the Australian Charities and Not for Profits Commission (ABN 25 135 595 578), The A21 Campaign Limited, a UK charitable company (no. 7335469) and A21 USA Inc., a Texan non-profit corporation

Links to third party websites.

The A21 website may provide links to third party websites for your convenience and information. If you access those links, you will leave the A21 website. A21 does not control those sites or their privacy practices, which may differ from this Privacy Policy. A21 does not endorse or make any representations about third party websites. Personal data you choose to provide to or that is collected by these third parties is not covered by this Privacy Policy. Please review the privacy policy of any organization before submitting your personal information to it

02 COLLECTION OF PERSONAL INFORMATION

To complete and record transactions, inform and serve you in connection with A21 activities and initiatives and better understand your needs and interests, A21 collects and uses appropriate personal information, having first obtained any required consents. A21 also files reports makes , along with required filings with data protection authorities, when applicable. For example, when you order products or services, request information, subscribe to marketing or support materials, register yourself as an A21 supporter or apply for a job at A21, we will ask you to provide personal information to complete these transactions and properly record and manage that relationship with you

The types of personal information you provide to us on these pages may include contact information such as your name, address, telephone number, email address, financial information such as your credit card number and other unique information such as user IDs, billing and transaction information, product and service preferences and contact preferences

Automatic Data Collection Tools

In addition to the information you provide, A21 may also collect information during your visit to our website through our Automatic Data Collection Tools, which include Web beacons, cookies, embedded Web links, and other commonly used information gathering tools. These tools collect certain standard information that your browser sends to our website such as your browser type and language, access times and the address of the website from which you arrived at an A21 website. With regard to A21’s use of cookies, we use session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. Although session cookies are established, they are not capturing any behavioral or personal information, only information that is helpful to the user experience, such as whether the user's browser has JavaScript capability. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies are being used to switch one time messages on and off and to record form completion

You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited. The use of cookies by third parties is not covered by our privacy policy. We do not have access or control over these cookies. Some third parties use session ID cookies to make it easier for you to navigate our site, for example, in order for you to use the shopping cart. Cookies, as well as the other tools listed above, may also collect information about your Internet Protocol (IP) address, clickstream behavior (i.e. the pages you view, the links you click, and other actions you take in connection with any A21 website) and product information. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers use IP addresses to communicate on the Internet, allowing users to browse and shop. A21 may also use some of these Automatic Data Collection Tools in connection with certain emails sent from A21 and therefore may collect information using these tools when you open the email or click on a link contained in the email

The A21 website operates social media features, such as the Facebook button and widgets like “Share this button” or interactive mini-programs. These features may collect your IP address or which pages you visit on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it

As part of its routine operations A21 also collects information from commercially available sources that it deems credible. Such information may include your name, address, email address, and demographic data. The information A21 collects from its commercial sources may be used along with the information A21 collects when you visit an A21 website. For example, A21 may compare the geographic information acquired from commercial sources with the IP address collected by Automatic Data Collection Tools to derive your general geographic area

On occasion, A21 may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personal information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as your post code or zip code)

03 HOW YOUR INFORMATION IS USED

The information A21 collects to understand your needs and interests helps us deliver a consistent and personalised experience

For example, A21 may use your information to

• assist you in completing a transaction or order
• notify you of changes to our services
• process a grant or job application
• send you communications which you have consented to, including newsletters and information about campaigns, fundraising and support activities, new services or initiatives and promotions of our goods and services
• provide and improve our events, services and support, including researching the demographics of our supporter base
• administer your account
• carry out our obligations arising from any contracts entered into with you
• comply with applicable data protection laws, including filing personal data breach reports with appropriate supervisory authorities or for other purposes disclosed to you at the time we collect your information, or pursuant to your consent, if applicable. For instance, a testimonial posted on an A21 website is only posted with the express permission of the individual or organization who provided it

The personal information collected when you make a contribution or purchase items by credit card is kept for the purposes of tracking your order and to provide a receipt of the transaction. Credit card information is used only for payment processing and fraud prevention. Credit card information and other sensitive personal information required to process a credit decision is not used for any other purpose by our financial services providers or A21 and will not be kept longer than necessary for providing the services, unless you ask us to retain your credit card information for future purchases

Consent and privacy preferences

A21 will give you the opportunity to choose your privacy preferences regarding the communications we send. You can update your choices or stop us sending you these communications at any time by contacting us on info@a21.org.

You may also opt out of receiving communications by selecting the email "opt out" or "unsubscribe" link, or follow the opt-out instructions included in each subscription communication. Return to the web page(s) where you originally registered your preferences and follow the opt-out instructions. Please be aware that when you opt out of receiving certain subscription communications, it may affect the services you have chosen to receive from us

04 KEEPING YOUR PERSONAL INFORMATION SECURE

A21 takes seriously the trust you place in us. We follow generally accepted industry standards to protect the personal information you submit to an A21 website. To prevent unauthorised access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information A21 utilises appropriate physical, technical, and administrative procedures to safeguard the information we collect

We use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information such as credit card information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see the symbol of either an unbroken key or a closed lock (depending on your browser) at the top or bottom of your browser window

As part of real-time payment processing, A21 subscribes to a fraud management service. This service gives you and A21 an extra level of security to guard against credit card fraud and to protect your financial data

For the protection of victims of human trafficking in the care of A21, all names and details pertaining to specific cases have been changed

05 LEGAL BASIS FOR PROCESSING PERSONAL DATA

A21 shall ensure that personal data is limited to what is adequate, relevant and necessary in relation to the purposes for which it is processed

All data must be processed by A21 on one of the following lawful bases - consent, contract, legal obligation, vital interests, public task or legitimate interests. Where your consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with your personal data

06 WHO ELSE HAS ACCESS TO YOUR INFORMATION

A21 retains service providers and suppliers to deliver complete products, services, and customer solutions and to assist with marketing and communication initiatives. These providers and suppliers include, for example, credit card processors, providers of customer support and live-help, email service providers, automated data processors and shipping agents

Suppliers and service providers are required by contract to keep confidential the information received on behalf of A21 and may not use it for any purpose other than to carry out the services they are performing for A21

From time to time, A21 participates in marketing initiatives with other companies. As part of these initiatives, certain services and marketing communications are delivered at the same time as those from other companies. Some of these services and communications offer you the option to share personal information with both A21 and the other companies participating in these initiatives. For example, you may receive marketing communications from A21 and other companies or have the opportunity to register online for software products from multiple companies

If you choose to provide personal information only to A21, we will not share this information with the other companies participating in that marketing initiative. If you choose to provide personal information to the other companies, that personal information will be handled according to the privacy policy of those companies

A21 may need to transfer your personal information to other A21 entities in Australia or the USA in accordance with this Privacy Policy for data storage or operational reasons or to satisfy certain requests you make. Your consent to such transfer is a requirement of you providing your information to A21

Except as described in this Privacy Policy, A21 will not share the personal information you provide with third parties without your express permission, unless to respond to duly authorized information requests of police and governmental authorities, comply with any law, regulation, subpoena, or court order, help prevent fraud or to enforce or protect the rights and properties of A21 or entities owned, controlled by or affiliated with A21, protect the personal safety of A21 employees, staff, contractors or other third parties on property occupied by A21 or when we believe in good faith that disclosure is necessary to protect your safety or the safety of others

07 CHILDREN’S PRIVACY

A21 does not knowingly collect personally identifiable information from children under the age of thirteen (13) without requiring parental consent and A21 does not target its websites to such children

Any person who provides information to us represents that they are thirteen (13) years of age or older. We encourage parents and guardians to take an active role in their children's online activities and interests. If you have any questions or concerns in this matter, please contact us on info@a21.org. If you believe we have inadvertently collected personally identifiable information from a child under age thirteen (13), please encourage the parent of the child to contact us, and we will provide the parent with an opportunity to review the data inadvertently collected, and further provide the parent an opportunity to have such data deleted and agree to prevent its further use or collection

08 DATA RETENTION

A21 only keeps data as long as is reasonable and necessary for the relevant activity or service. For instance, this may be determined by applicable statutory obligations such as the collection of Gift Aid or tax reporting, or to perform our obligations or exercise rights under any relevant contract A21 has with you

To ensure that personal data is kept for no longer than necessary, A21 reviews our retention periods for personal information on a regular basis. In light of this we have put in place a Data Protection Policy and will regularly review that policy. This policy shall consider what data should/must be retained, for how long, and why

09 YOUR DATA ACCESS & RIGHTS

A21 strives to keep your personal information accurately recorded. We have implemented technology, management processes, and policies to help maintain data accuracy. A21 provides you with reasonable access to the personal information you have provided and the ability to review and correct it online. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your data

If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. If there are any discrepancies in the information we provide, please let us know as soon as possible and we will correct them

It is important for you to be aware of the various rights you have in respect of the personal information we hold about you. These rights include:

• The right to request access to the personal information held about you
• The right to restrict the processing of personal data
• The right to object to the processing of your personal data
• The right to withdraw your consent at any time
• The right to rectify or erase the data held about you

If you wish to exercise any of these rights or make a complaint on how we have handled your personal data, you can do so by contacting our Data Protection Officer at dpo@a21.org.

Last Updated: 02 February 2023