Adara policies
Adara Development, Adara Advisors Pty. Limited and Adara Partners (Australia) Pty. Limited (collectively the Adara Group, we, us etc.) respect and are committed to protecting your privacy. This Privacy and Information Security Policy (Privacy Policy) applies to information we collect, including from your visit to the Adara Group website and the Adara Knowledge Centre website, or any other web properties or third-party sites managed by the Adara Group and governs data collection, storage and usage, including in relation to the sites (sites). By providing information to us and by using any Adara Group website, you consent to the data practices described in this Privacy Policy and you can be assured that the information you provide will only be used in accordance with this Privacy Policy. The Adara Group is based in Australia and endeavours to handle personal information in accordance with the Australian Privacy Principles (APPs) contained in the Australian Privacy Act 1988 (Cth) (Privacy Act).
Individuals in Europe
In addition to the Privacy Act, for individuals located in the European Union (EU) (including the European Economic Area (EEA)), the collection and processing of your personal information by the Adara Group, will be subject to the General Data Protection Regulation (2016/679) (GDPR) from 25 May 2018. The GDPR has harmonised the data privacy laws of each individual EU country, giving more rights to individuals located in the EU, imposing more obligations to organisations collecting and processing their personal information.
In providing our services to you, we may collect and process personal information as outlined below. Otherwise, including for individual users of our services, the Adara Group will be a data controller for the purposes of the GDPR, and where the Adara Group is a data processor it implements appropriate technical and organisational measures to ensure and to be able to demonstrate that the Adara Group’s processing is performed in accordance with the GDPR and ensure the protection of the rights of the data subject. This Privacy Policy includes information that must be provided to you when we collect your personal information.
Individuals in Uganda
For individuals located in Uganda, the collection and processing of your personal information by the Adara Group will be subject to the Data Protection and Privacy Act 2019. Our Uganda Privacy Policy contains the information that must be provided to you when we collect your personal information.
What we collect
We generally collect and hold only the personal information necessary for the Adara Group to pursue its business activities and charitable work and to fulfil associated administrative and other functions. Personal information is information or an opinion about a person that identifies an individual or from which the individual’s identity can reasonably be ascertained.
Most of the Adara Group’s website can be viewed without providing any personal information that could be used to identify you. However, if you wish to donate to Adara Development, submit an enquiry via our online contact form or request any information or online resources from us, we may ask you to provide personal information such as your name, email, postal address and/or phone number. Some of the individuals who donate to Adara Development are located in the EU. Please note that we only collect identifiable personal information from donors when it is voluntarily submitted. Where it is lawful and practicable, we will also allow individuals to deal with us on an anonymous basis or by using a pseudonym. For example, we can accept gifts and other forms of support anonymously. However, in some jurisdictions (e.g. the USA) provisions contained in taxation legislation require the Adara Group to collect the name of the donor if the donor requires a tax deductible receipt.
If you apply for employment, a volunteer or an internship position with us, we collect personal information about you, such as background, education and employment history and the other personal information referred to in our collection notice notified to you.
REQUEST FOR ONLINE RESOURCES
The Adara Group may create online resources from time to time, which will be made available by request on this website. If you wish to access the resources, we may ask for your personal information and seek your consent so that we can send you the resources via email, and provide you with updated information about the resources you requested. Without your personal information we may not be able to process your request. We will also provide you with an opportunity to opt-out of receiving updates about the resources.
How we store personal information
We regard the security of your personal information as a priority and implement a number of physical and electronic measures to protect it. We remind you, however, that the internet is not a secure environment and although all care is taken, we cannot guarantee the security of information you provide to us via electronic means.
We may store your personal information in paper-based form or electronically in our systems or in a database maintained by a cloud hosting service provider or other third party database storage or server provider. Backups of electronic information are written to drives which are stored offsite. Hard copy information is generally stored in our offices, which are secured to prevent unauthorised entry.
We aim to keep your personal information for only as long as we need it, or until you advise you would like it removed, unless we de-identify it or destroy it earlier in accordance with the APPs.
We may also transfer personal information to our overseas operations. Those recipients are generally located in Nepal, Uganda, the United States, the United Kingdom and Bermuda. Any such transfer, however, does not change any of our commitments to protect your personal information under this policy.
We will take steps to ensure that your personal information will be afforded the level of protection required of us under and in accordance with this Privacy Policy and applicable data protection and privacy laws, and in accordance with current legally recognised data transfer mechanisms, such as appropriate EC approved standard contractual clauses (see https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).
How we use your information
We can only collect and use your personal information if we have a valid lawful reason to do so. Personal information that is voluntarily submitted to us including on our website is used for the purpose for which it is submitted or for such other secondary purposes that are directly related to the primary purpose. Where we have your consent or are otherwise permitted by law to do so, we may also use your information to keep you informed about the activities of the Adara Group, about the projects and research funded by the Adara Group, and to ask for your support. We will not sell or trade in your personal information without your prior permission.
When you visit our website, or download information from it, our internet service provider, makes a record of your visit and records the following information: your internet address, your domain name (if applicable), the date and time of your visit to the website, the pages you accessed and documents downloaded, the previous website you visited and the type of browser you are using. This information is only used for statistical and website development purposes. We also make limited use of cookies on our website. Cookies are data that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies are industry standard and can facilitate a user’s on-going access to and use of a Web Site. When cookies are used on this site, they are used to store information relating to your visit such as a unique identifier, or a value to indicate whether you have seen a web page. This information allows us to customise the website to your needs. Most internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer, giving you the choice whether to accept it or not.
Opting out
Where we use your personal information to keep you informed about the activities of the Adara Group, about the projects and research funded by the Adara Group, to send you information and online resources you may have requested, and to ask for your support, by post, email or telephone, we will provide you with an opportunity to opt-out of receiving such information. By electing not to opt-out, we will assume we have your implied consent to receive similar information and communications in the future. We will always ensure that our opt-out notices are clear, conspicuous and easy to take up.
If you do not wish to receive these types of communications from us, please contact us at the Adara Group, Level 2 117, Harrington Street, the Rocks, NSW 2000 Tel: + 61 2 9395 2800 or email: info@adaragroup.org.
Disclosure
The Adara Group will only disclose personal information submitted if we have gained permission to do so. However, in order to achieve the purpose for which information is submitted, the Adara Group may disclose information to third parties, including government agencies, our consultants and service providers, such as commercial mail preparation services and cloud hosting service providers. To ensure that privacy is protected when the Adara Group uses third party service providers, we only do business with reputable service providers that have a strong Privacy Policy and on the condition that they do not use the data provided by the Adara Group for any other purpose. Personal information may also be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring or interfering (intentionally or unintentionally) with our rights or property, users or anyone else who could be harmed by such activities; or we believe in good faith that the law requires disclosure.
Any third party service providers to whom we disclose or permit access to your personal information in the course of providing services on our behalf will be subject to strict contractual restrictions to ensure that they protect personal information and keep it confidential, consistent with relevant privacy and data protection laws.
Access and complaints
In most circumstances, you can access any personal information which we collect and hold about you and have it corrected if it is wrong. Please contact our Communications Manager to ask for access to your personal information. We may deny your request for access to personal information in some circumstances or we may decline to correct personal information we hold. If we do this, we will tell you why.
If you would like to make a complaint relating to the manner in which we handle your personal information, please contact our Head of Legal, on + 61 2 9395 2800 or email complaints@adaragroup.org. We will respond to complaints and queries within a reasonable period from their receipt. If you are dissatisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner (see www.oaic.gov.au).
USERS OF THIS WEBSITE UNDER 18 YEARS OF AGE
This website is intended for general audiences and is not directed to users under 18 years of age. If you are younger than 18 years of age and wish to access online resources through this website, please ask your parent or guardian to request the resources on your behalf.
Individuals in the EU
You also have in certain circumstances: the right to request that the personal information that is collected from you is erased; the right to restrict further processing of your personal information; the right to object to further processing of your personal information; and the right to data portability. You can also ask that personal information provided by you to us is transmitted to another party. You may also withdraw your consent where it has been provided as a condition of our processing your personal information or object to the further processing of your personal information in certain circumstances.
If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision.
To make a request in respect of these rights please contact our Communications Manager at info@adaragroup.org. To make a complaint please contact the Adara Group at complaints@adaragroup.org.
You also have the right to lodge a complaint with a relevant data protection supervisory authority (for example in the place you reside or where you believe we breached your rights). The UK data protection authority is the Information Commissioner’s Officer (ico.org.uk). For other European jurisdictions please refer to the European Commission (http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).
Contact us
For the purposes of the GDPR, Adara Group is a data controller for our website and services provided through our website.
We can be contacted at:
Adara Group, Level 2, 117 Harrington St, The Rocks, NSW 2000 Australia
If you would like more information about our approach to privacy please email us at info@adaragroup.org or call + 61 2 9395 2800.