Versão 01.2021
Entrada em vigor: 01/06/2021



1. About this privacy policy

This privacy policy defines how ADRA-Brazil collects, uses and stores personal data through programs and services offered and also through the site: https://www.adra.org.br and was elaborated including the related national guidelines, such as the Marco Civil da Internet, the Access to Information Law, the Personal Data Protection Law, besides other legislations that regulate the activity developed by ADRA and its obligations before the public power.

In order to facilitate understanding, we use the pronouns “we” or “us” to refer to ADRA in Brazil.
The CONTROLLER of the data is ADRA Brasil CNPJ 01.467.063/0001-15 located at SGAS 611, Conjunto C, Parte D, Asa Sul, Brasília.

2. When do we collect information about you?

We collect information:
– when you provide them to us directly;
– when you provide them to us indirectly;
– when you provide them to us through social networks;
– when you use our websites or applications, through cookies.
– when you are a beneficiary of an inclusive or welfare program developed directly by ADRA or in partnership with public authorities.
 
DIRECTLY
You provide us with personal information when you: become a donor, regardless of the form or regularity of the donations (monthly or one-time, through the site, call-center, street action, direct mailing, payment of a bill, among other possibilities), register for one of our events, communicate with us, subscribe to our e-mail newsletter, and leave a comment on our social networks.
We also collect your information when you enroll as a beneficiary in any social program developed by us directly or in partnership with public authorities.

INDIRECTLY
We may receive your personal information through fundraising organizations or platforms when you claim to be supporting ADRA, but always with your consent. Please check the privacy policies of each company whenever you provide your data to third parties.
We may obtain your personal information through other organizations, provided that they ensure that the data was obtained with prior authorization. Please check the privacy policies of each company whenever you provide your data.

SOCIAL NETWORKS
We may obtain information about you from your social media accounts or services. We may do this if you have set your account settings to give us permission. Please check your settings and the social network’s privacy policies for more details.
 
3. What information do we collect?

If you contact us, we may collect your name, e-mail address, date of birth, gender, and landline or cell phone number or address (geo-location).

When you become an ADRA donor we will need to collect your CPF, bank or credit card information, and your date of birth to confirm that you are over 18.

4. How do we use your information?

As a general rule, your personal data will not be used for any purpose other than that for which it was voluntarily provided to us. Your personal data is shared or transferred to third parties if such transfer or sharing is authorized by you or is necessary to achieve the purposes for which you provided it to us.

This means that we may share your personal data with service providers that help us fulfill our purposes. For example, by registering for our newsletter, you consent to your personal data (name and e-mail address) being processed for the purpose of sending you e-mails. The geo-location of the recipient is requested so that the volunteer can indicate support locations. Personal data may also be shared with third parties when required by law or a court order.


We use your data to:

– handling your inquiries and requests;
– processing and acknowledging your donations; –
keeping a record of your relationship with us; –
sending you ADRA
updates, marketing and communications; –
understanding how we can improve our services and information;
– analyzing our fundraising activity;
– improve your navigation in the application.

How we use your data depends on why you are providing it to us:

ONLINE FORMS AND FEEDBACK
We will use your personal information to respond to your questions, requests, or to register you for events.
 
SEARCH
We use surveys to understand who visits our sites and how they are used, helping us to create better content for you and to make our sites easier to use.
We may ask for your email address if you are happy to participate in future surveys or tests. We will only use this to ask you to help us with these types of requests.

DONATIONS
We use your information to process and keep a record of your donations, in accordance with data retention legislation.

DIRECT MARKETING
We use direct marketing (targeted and customized to you) to let you know what ADRA is doing and how your support makes a difference. We may use it to ask for your help in raising more funds or for other support.
We will send you direct marketing by mail unless you indicate that you do not wish to receive contact from us in this way. We send these communications with your consent, and if you change your mind, you can request to be unsubscribed.
We will also send you direct marketing by e-mail, SMS and telephone, if you consent to receive contact from us in this way.
In the footer of each email, there are ways to deactivate or update your preferences in our direct marketing. You can opt-out at any time.

SOCIAL NETWORKS
We may use public information available in your profile to target specific posts that may interest you. We will never solicit personal or confidential information through our social networks. We may repost or share your social media posts if they relate to ADRA and our work. We may respond to questions, queries or comments left on our social media channels and ultimately may use information found in your profile to help us respond to them.
Check your social media accounts if you want to change the information you have made public and set the privacy levels to your preference.

5. Who has access to your data?
TRAINED PROFESSIONALS
Your information is only accessible to trained professionals. As a general rule, your personal data will only be accessible to the extent necessary to fulfill the purpose for which it was collected. For example, the data you provide for donations will be accessible to our donations department, our fundraising and marketing team, and service providers who are hired specifically for this purpose, if it is necessary to process your donation.

DATA OPERATORS
We use other companies to help us manage and perform activities on our behalf, but first, we have strict hiring and auditing criteria.
We operate globally and may need to transfer data from professionals working on international projects to countries outside Brazil. If the country to which the data is transferred does not provide an adequate level of protection, we make sure we implement technical and organizational measures to protect your data.

6. How do we keep your information secure?
We use appropriate technical and organizational measures and precautions to protect your personal data and prevent the loss, misuse or alteration of your personal data. As no system is 100% secure, in the event of a personal data breach incident, we will notify you immediately. 

7. How long do we keep your information?

We keep your information for as long as necessary for the purposes defined above. For example, as a general rule, we keep your email address for the purpose of sending you a newsletter until you unsubscribe. If you request not to receive any further contact from us, we will keep only the basic information about you on our (inactive) suppression list to avoid sending you unwanted material in the future.

8. Our legal basis for processing personal data
Organizations need a legal basis for collecting and using personal data under data protection law(s). (The law(s) allow six ways to process personal data (and additional forms of sensitive personal data). Three of these are relevant to the types of processing undertaken by ADRA:

– A person’s consent (for example, to send you direct marketing by email or SMS);

– Processing necessary to fulfill a legal obligation (for example, to process large donation or benefit claims); and

– Our legitimate interests (please read below for more information).

Our legitimate interests include:

Humanitarian aid governance; including the delivery of our humanitarian aid objectives, statutory and financial reporting, and other regulatory compliance purposes;

Operational administration and management; including responding to requests, providing information and services, research, event management, volunteer management, and employment and recruitment requirements.

Fundraising and campaigning; including campaign and donation management, and sending direct marketing and thank you letters by mail.

9. How can you change your information and what are your rights? 
Contact us at [email protected] if you want to change or update your personal information.

You have several rights under Art. 18 of the General Data Protection Act concerning data protection such as:

– Updating and correcting data;
– Revocation of consent;
– Information about the processing of your data;
– Data portability (transfer to another organization of the same nature);
– If you have any further questions about the way your data is being used, or if you wish to make a complaint, please contact us using the means already mentioned.
– Deleting the data;

In all cases we will ask for additional information to prove your identity. Don’t worry, it’s for your safety!

10. When do we update this policy? 
We update this Privacy Policy when necessary. If we make significant changes in the way we treat your personal information, we will make that clear on our websites or contact you directly.

11. Additional
The policies presented are applied to donors, volunteers and beneficiaries; however, there is a special treatment for beneficiaries’ data that will not be shared under any circumstances with third parties, only with the public authorities when requested to execute public policies, comply with a legal obligation or a court order.

12. Data Clerk
Our personal data protection officer is Dr. Stéfanne Amorim Ortelan who can be reached at [email protected]