1. Introduction

Stichting Friends for Townships (“the Foundation”, “we”, “us”) is committed to protecting the personal data of everyone who interacts with us — whether you donate, subscribe to our newsletter, or simply contact us.

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have. It applies to all processing of personal data by the Foundation and is governed by the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Dutch Implementation Act (“UAVG”).

Even if you reside outside the European Union, this policy applies to you. Because the Foundation is established in the Netherlands, the GDPR applies to all data we process, regardless of the donor’s country of residence.

2. Who We Are (Controller)

The data controller responsible for your personal data is:

Stichting Friends for Townships

Bronovolaan 1 B 6, 2597AX The Hague, The Netherlands

Email: support@friendsfortownships.org

KVK: 42004416

We have not appointed a Data Protection Officer (DPO), as this is not currently required for an organisation of our size and nature. Questions about data protection can be directed to support@friendsfortownships.org.

3. What Data We Collect

3.1 Donation data

When you make a donation, we collect:

First and last name
Email address
Country of residence
Donation amount, currency, and date
Selected project (if applicable)
Donation type (one-time or recurring)
Transaction reference number (provided by the payment processor)

We do not receive or store full payment credentials (card numbers, IBAN, etc.). These are handled exclusively by our payment service provider.

3.2 Newsletter subscriptions

If you subscribe to our newsletter via Enormail, we collect:

Email address
First name (optional, for personalisation)
Date and method of subscription
Subscription status and opt-out history

3.3 Contact form

If you use the contact form on our website, we collect:

Name
Email address
The content of your message

3.4 Website usage data

We use Google Analytics to understand how visitors use our website. Google Analytics collects anonymised data such as:

Pages visited and time spent
Browser type and device
Approximate geographic location (country/region level)
Referral source (how you arrived at our site)

We do not use Google Analytics to identify individual visitors. IP addresses are anonymised before processing. We will implement a cookie consent mechanism on the website in compliance with the Dutch Telecommunications Act (Telecommunicatiewet) before activating Google Analytics.

4. Legal Basis for Processing

We only process your personal data where we have a valid legal basis. The bases we rely on are:

4.1 Performance of an agreement / processing a transaction

Donation data is processed to execute and administer your gift, issue confirmations, and manage recurring donations. This constitutes execution of a (gift) agreement under Article 6(1)(b) GDPR.

4.2 Compliance with a legal obligation

We are required to maintain financial records under Dutch accounting and tax law. Donation records are retained in compliance with these obligations under Article 6(1)(c) GDPR.

4.3 Legitimate interests

We use aggregated website analytics data to improve our online presence and make our communications more relevant. We have assessed that this processing does not override your interests or fundamental rights under Article 6(1)(f) GDPR.

4.4 Consent

Newsletter subscriptions are based on your freely given, explicit consent under Article 6(1)(a) GDPR. You may withdraw this consent at any time, free of charge, without affecting prior communications.

5. How We Use Your Data

We use your personal data for the following purposes:

Processing and confirming your donation.
Administering recurring donations, including the scheduling and collection of future payments.
Sending you donation confirmations and updates about the project you supported.
Sending you our newsletter, if you have subscribed.
Responding to your enquiries via the contact form.
Improving our website using anonymised analytics data.
Complying with our legal obligations under Dutch law.

We do not use your data for automated decision-making or profiling. We do not sell, rent, or trade your data to any third party. Ever.

6. Who We Share Your Data With

We share personal data only with the service providers strictly necessary for our operations:

6.1 GiveWP / Payment processor

Donation transactions are processed by GiveWP and the underlying payment gateway. These parties receive the data necessary to complete the transaction. They act as data processors under a processing agreement with the Foundation.

6.2 Enormail

Newsletter distribution is handled by Enormail, a Dutch email service provider. Subscriber data (email address, name) is stored on Enormail’s servers. Enormail processes this data solely on our behalf.

6.3 WordPress hosting provider

Our website is hosted on a third-party server. Website data, including contact form submissions, is stored on that server. The hosting provider does not access this data for its own purposes.

6.4 Google Analytics

Anonymised usage statistics are shared with Google LLC via Google Analytics. Google may process this data in the United States. We use IP anonymisation and have configured the service to minimise data transfer. We will establish a Data Processing Agreement with Google before activating this service.

We do not share personal data with the partner organisations in South Africa (schools, children’s homes, disability centres). Donor information remains within the Foundation’s administration.

We do not share personal data with any other third parties, unless required to do so by law or a court order.

7. International Transfers

The Foundation is based in the Netherlands (EU). Most of our data processing takes place within the European Economic Area (EEA).

Google Analytics may involve the transfer of anonymised data to the United States. Google LLC is certified under the EU-US Data Privacy Framework, which provides an adequate level of protection for personal data transferred from the EU.

All other data processing takes place within the EEA.

8. Retention Periods

We retain personal data only as long as necessary:

Donation records: 7 years from the date of the donation (required by Dutch tax and accounting law).
Recurring donation data: for the duration of the recurring arrangement, plus 7 years.
Newsletter subscriber data: until you unsubscribe, after which we delete your data within 30 days.
Contact form data: 12 months after the correspondence is closed.
Website analytics data: 26 months (Google Analytics default, may be reduced).

After the applicable retention period, data is deleted or anonymised.

9. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

Right of access: you may request a copy of the personal data we hold about you.
Right to rectification: you may request that inaccurate data be corrected.
Right to erasure: you may request deletion of your data, subject to our legal retention obligations.
Right to restriction: you may request that we limit the processing of your data in certain circumstances.
Right to data portability: you may request your donation and subscription data in a structured, machine-readable format.
Right to object: you may object to processing based on legitimate interests, including the use of analytics data.
Right to withdraw consent: for newsletter subscriptions, you may withdraw consent at any time via the unsubscribe link in any email or by contacting us.

To exercise any of these rights, contact us at support@friendsfortownships.org. We will respond within one month. In complex cases, we may extend this period by two further months, and we will inform you if we do so.

You will not be charged for exercising your rights. However, we may refuse manifestly unfounded or excessive requests.

10. Complaints

If you believe we are not handling your personal data correctly, you have the right to lodge a complaint with the Dutch supervisory authority:

Autoriteit Persoonsgegevens (AP)

PO Box 93374, 2509 AJ The Hague, The Netherlands

Website: www.autoriteitpersoonsgegevens.nl

Telephone: +31 (0)88 1805 250

We would, however, appreciate the opportunity to address your concern directly before you contact the AP. Please reach out to us first at support@friendsfortownships.org.

11. Cookies

Our website uses cookies. A cookie is a small text file stored on your device when you visit a website.

We use the following types of cookies:

Functional cookies: strictly necessary for the website to function (e.g. session management, the donation form). These do not require consent.
Analytical cookies: used to analyse website usage via Google Analytics. These are activated only after you have given consent via our cookie banner.

You can manage, block, or delete cookies via your browser settings. Note that blocking functional cookies may affect the performance of the website and donation process.

Our cookie banner will be implemented prior to activating Google Analytics, in compliance with the Dutch Telecommunications Act.

12. Security

We take the protection of your personal data seriously. We implement appropriate technical and organisational measures to prevent loss, unauthorised access, misuse, or disclosure of your data. These include:

HTTPS encryption on all website pages.
Access controls limiting who within the Foundation can access donor data.
Processing agreements (verwerkersovereenkomsten) with all service providers who handle personal data on our behalf.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay, as required by Article 34 GDPR.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The most recent version will always be published on our website at www.friendsfortownships.org. We will notify you of material changes by email if you are a donor or newsletter subscriber.

The date of the most recent revision is shown at the top of this document.

14. Contact

For any questions or requests regarding this Privacy Policy or your personal data:

Stichting Friends for Townships

Bronovolaan 1 B 6, 2597AX The Hague, The Netherlands

Email: support@friendsfortownships.org

Website: www.friendsfortownships.org