What personal data does Promly collect and process?
“Personal data” means any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Special categories” of personal data refers to information concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise makingavailable, alignment or combination, restriction, erasure or destruction. Promly processes all or some of the following personal data provided by you or whichyou provide to third parties and is shared with Promly:
Your name, address, city of residence, email address, telephone number, age,educational history, employment or professional related information, social history, names of individuals connected to you, demographic information, device identifiers, or other information, that you may provide to us that might reasonably be used to identify you personally or someone connected to you.
How do we collect your personal data?
Promly will collect personal data when it is provided to us by you in face-to-face or telephone conversations, an email, on a registration form or any other forms requesting users, volunteers or donors to provide personal data, in an online survey, or in other similar transmissions. For example, the Websites may offer you registration forms, or other fillable forms that ask users to provide personal data.
What are Promly’s legitimate interests in collecting and processing personal data?
Promly is a nonprofit /public benefit hybrid organization that exists to protect emotional health and prevent suicide for our nation’s teens and young adults. We partner with high schools and colleges to strengthen their mental health, substance abuse and suicide prevention programs and systems. We equip teens and young adults with the skills and knowledge to help themselves and each other. We encourage community awareness, understanding and action for young adult mental health. Promly processes personal data of users, donors and volunteers to further its charitable mission and for the following business purposes:
• To fulfill a transaction initiated by or involving a user, volunteer or donor;
• To raise funds and awareness in support of our mission of suicide preventionand education;
• To process and document charitable donations;• To contact you;• To maintain our Websites and provide user support;
• To provide educational and marketing materials;
• To maintain the security of personal data collected and processed and of our websites;
• To provide data to our educational and other partners;
• To provide training;
• To manage our databases;
• To provide for volunteer and donor opportunities;
• To meet our legal, regulatory and compliance obligations.
What are Promly’s lawful basis for processing personal data?
Promly is committed to processing personal data only where there is a lawful basis, such as:
• The Data Subject has given consent to the processing of his or her personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the Data Subject is a party or in order to take steps at the request of the Data Subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which Promly is subject;
• Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Promly;
• Processing is necessary for the purposes of the legitimate interests pursued by Promly or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of personal data, in particular where the Data Subject is a child.
• Processing of special category personal data shall only occur where the DataSubject has given explicit consent to the processing of the personal data for one or more specified purposes or where permitted by applicable law.
Does Promly use the collected information to contact you?
From time to time would like to use the personal information we collect to contact you or to send you news and information relating to Promly initiatives, events, and other pertinient news. By providing personal information to us, you consent to us contacting you for this purpose. You may select the unsubscribe option on email updates you receive from Promly or one of our sites if you do not wish to receive the updates.
Does Promly share the collected information with third parties?
We would also like to pass on the personal data we collect with our affiliates, contractors and other third parties where applicable legal requirements are met and there is a legitimate business purpose for sharing the information. For example, Promly may use personal data to help diagnose problems with our servers and to administer the Websites. By providing personal information to us, you consent to us passing on your details for that purpose.
Promly may also disclose personal data to third parties if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on Promly or its subsidiaries or affiliates; (b) protect and defend the rights or property of Promly or the users of Promly, and (c) act under exigent circumstances to protect the personal safety of users of Promly or the public.
Does Promly provide links to third-party sites?
The Websites may provide links to one or more third-party websites. Even if a third-party website or the third party is affiliated with Promly (through a business partnership or otherwise), Promly is not responsible for the privacy policies or practices or the content of such third-party websites. We encourage you to read the privacy policies of the third-party websites you may link to by visiting their websites.
What steps does Promly take to secure your personal data?
Promly implements appropriate technical, administrative and physical safeguards to protect the confidentiality, integrity and availability of the personal data we obtain from you taking into account the nature of the data, emerging threats, the risks of collection and processing, best practices for securing the data and the associated cost of implementation. Unfortunately, data transmission over the Internet cannot be guaranteed to be secure, nor is any information system completely secure. Promly does not guarantee the security of any information you transmit to us or provide to us online.
Does Promly transfer personal data across borders?
Personal data we collect from you may be transferred outside the country where you reside in compliance with applicable law. The Websites are operated and maintained within the United States. Although you may access our Websites from outside the United States, any personal data collected by Promly may be transferred, processed or used in the United States. By using our Websites or providing personal data from outside the United States, you consent to the use of your personal data in the United States.
Does Promly seek parental consent to process personal data from children under the age of 13?
The Websites are not directed at children under the age of 13. If Promly knows that a user is under the age of 13, we will NOT intentionally:
1. Collect Personal data without prior parental consent;
2. Collect online contact information from that user without prior parental consent;
3. Collect personally identifiable offline contact information from that user without prior parental consent;
4. Give that user the ability to distribute personally identifiable information without prior parental consent;
5. Distribute to third parties any Personal Data of that user without prior parental consent; and
6. Entice that user by the prospect of a special game, prize or other activity, to divulge more information than is needed to participate in the activity.
Do you have rights in your personal data?
You have the following rights in your personal data held by Promly:
1. The right to access your personal data and request certain information concerning your personal data, such as an explanation of the purpose of the processing and disclosure of third parties with whom Promly shares the data;
2. The right to rectify inaccuracies in your personal data or to ensure that it remains up to date;
3. The right to erasure of your personal data under certain circumstances. For example, you may request erasure if the data is no longer needed in connection with the reasons it was collected or processed or if you withdraw your consent to further processing. Promly may deny your request where it is required or permitted by law to retain your personal data or when we need to retain you information in connection with the exercise or defense of legal claims;
4. The right to restrict processing where you contest the accuracy of the data in order to permit time to rectify the inaccuracies and in other circumstances;
5. The right to data portability by requesting a copy be provided in a structured, commonly used and machine-readable format and/or requesting that Promly transmit your personal data to a third party where technically feasible;
6. The right to object to processing of your personal data where you contest that the processing is necessary for the purposes of Promly’s or its business partners’ legitimate interests. Promly may deny your request because it has compelling legitimate business interests or the exercise or defense of legal claims. You may also advise us at any time that you no longer wish to receive direct marketing materials from Promly; and
7. The right to bring a complaint before the applicable governmental privacy regulator.You may contact the data privacy officer concerning your rights.
Promly gives you the following options for reviewing, changing, or removing your personal information from our database in order to stop receiving future communications:
1. You can send email to: firstname.lastname@example.org
2. You can send mail to the following postal address:
20 Community Place,
4th Floor Morristown,
If you have any questions about this Privacy Statement, the practices of this site, or your dealings with Promly, please feel free to contact:
Inc.20 Community Place,
We do not retain your personal data for longer than is necessary to fulfill the business purposes for which the information is being collected or processed or in order to comply with applicable legal or regulatory requirements. Personal data will be maintained for at least their minimum time period required retention under Promly’s records retention schedules.