Last updated: 01/11/2022
INFORMATION COV COLLECTS AND USES
We may collect information about you when you visit our site, contact us, make a donation, sign up to receive information from us, or register as an event participant, volunteer, or intern. The following sections explain how and why we collect, use, and disclose your personal information, which we define as information that identifies, describes, or is reasonably capable of being associated with you. The first two sections describe the information collected in an anonymous form (i.e. that does not identify you).
In general, we automatically gather certain usage information, such as the number and frequency of visitors to this website, and what features of the website are most popular to our visitors. This information may include which URL you just came from, which URL you next go to, what browser you are using, and what features you click on and read (in whole or in part). This collective data helps us to determine how much our visitors use parts of the website, and to do internal research on our users’ demographics, interests, and behavior, so as to better understand and serve you. In addition, we may aggregate data and disclose such information in a non-personally identifiable manner for research purposes only, and never for commercial gain.
We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.
Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.
Event participant, volunteer, and internship information
When you volunteer, participate in a Children of Vietnam-sponsored event, sign up to receive information from COV, or begin an internship with us, we may ask you for your name, email address, phone number, and other information relevant to the transaction. Personal Data may include your name, postal address, telephone number, email address, name of current school/college/university (if applicable), or affiliated club or organization.
When you use or access our website to make donations, we collect information about the transaction, as well as other information associated with the transaction such as name, postal address, telephone number, email address, payment information, amount donated, and the name(s) of any honoree(s) or person(s) for whom the donation was made in memory of. We use industry-standard safeguards to protect your information. Many donors use credit cards for donations. COV protects the security of credit card transactions using a number of measures such as encryption, access controls, network firewalls, and physical security. We also require the companies we work with to process your online donation payments using industry standards. These measures make it extremely difficult for anyone to intercept the credit card information you send to us.
Additionally, COV may use PayPal and other third-party service providers to complete the donation process depending on the platform you are using to donate. To the extent any donations are processed through third-party service providers such as, but not limited to, PayPal and Facebook, donors’ information is used solely to complete the donation transaction. Please access the respective privacy policies of these third-party service providers for further information on how they safeguard users’ personal data.
HOW COV DISCLOSES YOUR INFORMATION
We may disclose aggregated, anonymized, and/or non-identifying information about our users without restriction. We may use the information provided to us in our programs and activities, and enter your information into one or more of our databases so COV can contact you to provide information about our programs and events, or request donations.
Occasionally, COV may share your information with partners and vendors that assist us with our events and programs. As an example, COV may share information with vendors that help us to fulfill orders, manage data, and process donations and credit card payments. COV’s vendors are bound by confidentiality rules and are permitted to use the information only to fulfill their transactions with COV.
We may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
HOW YOU CAN ACCESS AND CORRECT YOUR INFORMATION
You may send us an e-mail at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, or cause the information to be incorrect.
Our website is not intended for children under 16 years of age. No one under the age of 16 may provide any personal information to us through our website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information through either of our websites, or on or through any of their features/functionality, use any of the interactive or public comment features that may be available on our websites, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn that we have received personal information from a child under 16without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child, please contact us at [email protected] and we will remove that information.
HOW COV SECURES YOUR DATA
We have implemented measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the website.
NOTICE TO USERS FROM THE EUROPEAN ECONOMIC AREA
Where we are offering or providing services to you and you are located in a member state of the European Union (“EU”) or European Economic Area (“EEA”), we will observe the EU General Data Protection Regulation (“GDPR”) and other applicable data protection laws when we collect and handle your personal information. In these circumstances, the following additional provisions apply.
Lawful Basis for Processing Personal Information
Transferring your personal information outside the EEA
The personal information that you share with us will be transferred to and stored at, a destination outside the European Economic Area (“EEA”) where laws may not currently be considered as meeting the same legal standards of protection for personal information as set out under GDPR. Your personal information may be processed by staff operating outside the EEA who work for us or our data processors. We will take steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the requirements under GDPR.
Retaining your personal information
COV retains your personal information for as long as you have a relationship with us; as necessary to perform our obligations to you (or to enforce or defend legal claims); or as is required by applicable law. The criteria we use for determining personal information retention periods are based on various legislative requirements; the purposes for which we hold personal information and whether retaining the personal information is needed in connection with that purpose; and further specific guidance issued by relevant regulatory authorities on personal information retention/erasure, including but not limited to, EU regulatory authorities.
Special Categories of Data
We request that you do not send to us (unless we specifically request) any Special Categories of Data, which is defined under the GDPR as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric characteristics, health, or sexual orientation.
Your personal information rights
If your personal information is subject to the GDPR, you have various privacy rights, which are as follows:
- Access: the right to be provided with a copy of your personal information that we maintain (the right of access).
- Rectification: the right to request that we correct any mistakes in your personal information.
- Delete: the right to request that we delete your personal information in certain situations.
- Restriction of processing: the right to request that we restrict processing of your personal information – in certain circumstances, e.g. if you contest the accuracy of the information.
- Objection: the right to object at any time to your personal information being processed for direct marketing; and in certain other situations to our continued processing of your personal information.
If you are not located in the EEA, you may still make one or more of the above requests. However, it will be at COV’s discretion whether to comply.
If you make a request and are not satisfied with our response, or believe that we are illegally processing your personal information, you have the right to complain to a data protection supervisory authority in your EU country of residence.
If you make a request that is manifestly unfounded, excessive, or repetitive we may charge you a reasonable administrative fee before complying.
If you would like to exercise any of the rights set out above, please contact us at [email protected]. We may need to ask for additional information to verify your identity before we can process your request.
Email us: [email protected]