(Version date: 1 December, 2021)

WWF Caucasus Programme Office (“WWF”, “WWF Caucasus, “we” or “us”) respects your privacy and we treat and view your personal data seriously. This personal data and privacy policy (“Personal Data and Privacy Policy”) applies to all staffs, supporters, Volunteers, visitors, contractors and users of our site pursuant to the requirements of the Law of Georgia on Personal Data Protection and law of Georgia of the State Inspector Service (this page outlines WWF’s policy in relation to data protection).
Personal Data shall include information concerning name as per identity card, preferred name, identity card number, age, contact number, residential address, e-mail address, birth date, gender, occupation, designation, bank account details, information of spouse/ children such as name and birth date, information as to physical or mental health, political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of an offence and other such data necessary for access and use to our Site and Services.
By accessing or using our Site, accepting our Services, making a donation or applying to be a Volunteer with WWF, you consent to the collection, use, disclosure and processing of your Personal Data as set out in this Personal Data and Privacy Policy. You may withdraw your consent at any time by submitting your written request to us at the contact details below.
At WWF Caucasus we rely on the support of individuals like you to carry out our vital conservation work. That is why we want to be completely transparent about why we need the personal data we request when you engage with us and how we will use them.
 
As you browse our website and whenever you communicate with us, we collect data. Collecting these data helps to make our communications more effective and to achieve our goals. The more data we have, the more efficiently we are able to operate and the more funds we can direct into conservation. In this privacy policy we explain why and how we process your personal data.
 
We take protecting your privacy very seriously and will always take all reasonable steps within our power to make sure your information is safe.
 
This privacy policy applies to all personal information we collect or process about you.
 
‘Personal information’ is information, or a combination of pieces of information, that could reasonably allow you to be identified.
 
We may update this policy from time to time without notice to you, so please check it regularly.
  
1.    WHEN WE COLLECT DATA
 
For example, we collect data when you:
·       Become a supporter of WWF
·       Participate in an event of WWF or volunteer with us
·       Make a donation to us
·       Buy any of our virtual gifts
·       Subscribe to our e-newsletters or request information from us
·       Sign a petition or become involved with one of our campaigns
·       Visit one of our websites or social media pages via tools such as cookies and online identifiers, including if you make comments on our message boards or discussion forums
·       Apply for a job or consultancy with us
·       Contact us or become involved with us in any other way than as stated above
 
WHAT DATA WE COLLECT
The type and quantity of data we collect and how we use it depends on and is restricted to why you are providing it. The data we may collect from the different sorts of interactions may include, but is not limited to:

• Your name, address, telephone number, and/or email address, along with your preferences as to how we should contact you in the future

• Financial information which you give to us, such as credit card number

• Information you enter onto our website

• Records of your donation history and correspondence and campaign actions taken with us

• Images, photographs or video if you take part in an event with us

• Details of your visit to the website, including technical information such as the IP address you use to access the website, your browser type and version

• Any other details in which you give us including your reasons for supporting us

 
We might also obtain personal data about individuals who may be interested in giving major gifts to organizations like ours. In these limited cases only, in addition to information you give us directly, we may also collect information about you from publicly available sources.
 
Children under 16 years
Not yet 16 years old? Then ask your parents for permission to engage with us on our website. Have them read this privacy policy.
WWF Caucasus does not intend to collect data about visitors of our website that are younger than 16 years old. However, we cannot check the age of the visitors of our website. If you think we have collected data of a minor without parental permission, please contact us at office@wwfcaucasus.org so that we can delete this information.
 
HOW WE COLLECT DATA ABOUT YOU
We use different methods to collect data from and about you including through:
Direct Interaction
We get information directly from you, for example when you subscribe to our e-newsletters. For information about when we may collect data about you, see above under WHEN WE COLLECT DATA.
 
Automated technologies or interactions
If you enter your details onto one of our online forms, and you don’t ‘send’ or ‘submit’ the form, we may contact you via email to see if we can help with any problems you may be experiencing with the form or our websites.
Similarly, if you receive an email, open it, don’t open it, select a link, browse our website, we collect this information so we can see which stories are popular and which aren’t.
 
When we’re seeing what people do online like this, we’re using cookies. If you don’t want cookies, you can set your browser to notify you when you receive one, then choose to decline it. Please read our Cookie Policy for more information.
Please note that if you disable or refuse cookies, then some parts of our websites may become inaccessible or not function properly.
 
Social Media
We may obtain your personal information through your use of social media such as Facebook, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media services. To changes your settings on these services, please refer to their privacy policies which will tell you how to do this.
 
Desktop Research
We may use desk research, profiling and screening techniques to analyze your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you, to be prepared when we meet you or to help us find others like you who might like to show their support. We do this because it allows us to target our resources more effectively, which donors consistently tell us is a key priority for them. We may make use of additional information about you, including geo-demographic information and measures of affluence, when it is available from third party sources. We may on occasion use third party suppliers to undertake these activities on our behalf and provide them with your information to the extent required.
 
Such information is compiled using publicly available data about you, for example addresses, listed Directorships, social media posts, newspaper articles or typical earnings in a given industry. This helps us understand the background of the people who do or may support us and helps us to make appropriate requests for gifts to supporters and/or leave us a gift in their will. Collating this publicly available information helps us better understand your motivations and preferences enabling us to deliver a more targeted and relevant donor experience. Additionally, it enables us to raise more funds, sooner, and more cost-effectively than we otherwise would.
 
WHAT WE USE THE DATA FOR
We will mainly use the data we collect to:
·       Provide you with the services, products or information you have requested
·       Keeping you up to date with the work you are supporting and the latest conservations news
·       Keeping a record of your relationship with us
·       Administering your donation
·       Asking for financial and non-financial support
·       Manage your communication preferences, including marketing preferences
·       Understanding how we can improve our services, products or information
·       Carrying out our obligations arising from any contracts entered into by you and us
·       Sending you tailored communications and displaying relevant adverts which we think will be of interest to you
·       Sending you marketing materials including on fundraising, campaigning and events
·       Inviting you to events and to take part in campaigns and support our advocacy work
·       Analyzing our database for statistical purposes, and to better communicate with you about things we think will be of interest. Note that this is on a generic rather than an individual level to ensure that our communications are cost effective
·       In limited circumstances, analyzing the personal information we collect about you and using publicly available information to better understand your interests, preferences and level of potential donations so that we can contact you more effectively and be better prepared in special circumstances when we may meet with you.
OUR LEGAL BASIS FOR PROCESSING DATA
All of our use of personal data is in accordance with the law. The law requires us to only process data where we have a valid legal basis for doing so. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you, such as providing you with the service you have requested.

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. WWF Caucasus Programme Office legitimate interests include administering our organization, sending you marketing materials, and understanding our supporters.

• Where we need to comply with a legal or regulatory obligation.

• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending email or text message direct marketing communications about fundraising, campaigns and events.

 
5. WHAT WE COMMUNICATE WITH YOU ABOUT
WHAT YOU HAVE REQUESTED
We communicate with you about what you have asked us to – to provide the service you have requested. For example, if you have signed up to a campaign, we will keep you in touch with our campaigns. We will keep you up to date with the latest conservation news and updates.
 
MARKETING
In addition to conservation news and updates on our work, we may also contact you about fundraising, campaigning and events.
 
Fundraising – your support is vital to our work and without you we would not be able to continue our conservation efforts. We may ask you to make a donation, upgrade your support or change its type. We may also invite you to special supporter events.
Campaigns – we’d love to tell you about our campaigning activities so that you can get involved.
Events – we’d love to tell you about the events organized by us, such as Earth Hour which we’d love you to get involved with.
 
The law distinguishes between the channels you choose to receive this information, and so we give you different options when we ask to use your data in this way.
 
We will always ask for your consent if we want to message you by email or text message, however we do not normally ask for consent to contact you by phone or write to you in other ways about any of the above activities (regarding fundraising, campaigning or events). This is because, as a charity, each of these activities is fundamental to how we work, so we have a legitimate interest to contact you. When you give us your details, we will tell you what we are going to do with them. You will always be given the opportunity to opt-out of receiving our marketing communications if you prefer not to.
You can unsubscribe at any time - see HOW TO CHANGE THE WAY WE CONTACT YOU for further information.
 
While we don’t usually ask, there are some instances where we may have expressly asked you for consent to receive telephone calls or letters from us (for example, if you gave us your details through our fundraisers in person). If you have consented for us to contact you in these ways, we will continue to do so unless you tell us not to.
 
In addition, where you have visited our online shop and provided us your details, then we may send you information about similar products which we think will be of interest to you, where you have not opted out of receiving such information. We will also always provide an opportunity for you to opt-out in every communication we send you about these products.
 
6. WHO WE SHARE YOUR DATA WITH
NOT TO THIRD PARTIES FOR THEIR MARKETING
We do not sell or share personal data to third parties for the purposes of marketing.
 
SERVICE PROVIDERS / SUPPLIERS
We do not undertake all of our processing activities ourselves and we may appoint suppliers to perform services on our behalf (e.g. payment processing). In such cases, we ensure that we have a contract with the supplier and as part of that agreement the supplier agrees to respect the security of your personal data and to treat it in accordance with the law. We only permit suppliers to process your personal data for specified purposes and in accordance with our instructions.
 
SOCIAL MEDIA
Depending on your settings or the privacy policies for social media and messaging services like Facebook and Twitter, you might give us permission to access information from those accounts or services. For example, we occasionally participate in Facebook’s “Custom Audience” program which enables us to display ads to our existing or potential supporters via Facebook. We provide personal information such as your email address to Facebook to enable them to determine if you are a registered account holder with Facebook. Our adverts may then appear when you access Facebook and on your Facebook feed. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account. For more information please read the Facebook Business page about Custom Audiences and Facebook’s Data Policy.
 
WHERE REQUIRED
In other cases, we will not disclose any of your personal data except in accordance with this policy, or when we have your consent, or under special circumstances, such as when we believe in good faith that the law requires it or to protect the rights, property and safety of WWF, or others. This includes disclosing your details if required to the police, regulatory bodies or legal advisors, if we are so requested.
 
7. HOW WE KEEP YOUR DATA SAFE
We aim to ensure we have appropriate physical, technical and managerial controls in place to protect your personal details; for example, our online forms are always encrypted and our network is protected and routinely monitored.
 
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Whilst we hope it will never happen, we have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are required to do so.
When we use external companies to collect or process personal data on our behalf we undertake due diligence on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, including keeping and using your data securely.
 
Our website may from time to time contain links to third party websites. If you follow a link to any of these websites, please note that these websites will have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Despite all of our precautions however, no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we strive to protect your personal information, we cannot guarantee the security of any information which you disclose to us and so wish to draw your attention that you do so at your own risk.
 
8. KEEPING YOUR INFORMATION UP TO DATE
We really appreciate it if you let us know if your contact details, or circumstances change.
 
9. HOW LONG WE KEEP YOUR DATA FOR
We will only keep your personal information for as long as is necessary for the purpose for which it is collected, which may include the purpose of satisfying any legal, accounting or reporting requirements. If you request that we stop sending you marketing materials we will keep a record of your contact details and the appropriate information to enable us to comply with your request not to be contacted by us.
 
RETENTION OF YOUR DATA
In order to determine how long we keep your data we look at the category of data and the reason we collected and have processed it. We look at whether that reason is ongoing, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve these purposes through other means, and the applicable legal requirements.
Legacy income is important for our organization. We may keep data you provide to us indefinitely to carry out our legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyze the source of legacy income we receive.

10. WHAT TO DO IF YOU DON’T WANT US TO COLLECT DATA ABOUT YOU
If you don’t want us to collect information about you as you browse our website you’ll need to set your browser to notify you when you receive a cookie, then choose to decline it.
If you don’t want us to hold any personal details about you, it’s best just not to give them to us. If you want us to stop collecting information about you or processing that information then please let us know. 
 
WITHDRAW CONSENT
Where we have asked you for consent to process your data, you may withdraw this consent at any time by contacting us at: (+ 995 32) 2237500 
 
COMPLAINTS
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.
 
If you have a complaint then please contact us using this link or by e-mailing us at complaints_ge@wwfcaucasus.orgin the first instance and we hope to be able to resolve your complaint. If, however, you believe that we have not been able to assist with your complaint or concern and you believe we are not respecting your rights, you are entitled to make a complaint to a relevant supervisory authority.
 
11. CHANGES TO THIS POLICY
 
We may amend or update this policy at any time to take account of any changes to data protection law or other legislation. When updates to the policy are made they will be posted on this page, so you may wish to check this policy each time you submit personal data to us.
  
CONTACT US
If you have any questions, please contact us using the details below:
Email: office@wwfcaucasus.org
Address: 11 M. Aleksidze Street, 0193 Tbilisi, Georgia