Changes to the Privacy Policy
From time to time, we may amend this Privacy Policy by posting it to the site and changing the date on this page noting when it was last updated. Your continued use of the site following the posting of any changes shall constitute your acceptance of the revised Privacy Policy.
EU/UK/Canada Privacy Notice
If you are a resident of the European Union (EU)/European Economic Area (EEA), United Kingdom or Canada whose personal information we collect, the following additional information applies to you.
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Introduction
1.1 – Where you are an EU/ EEA, UK, or Canada resident and AOA knowingly collects your personal information (also called ‘personal data’), we will do so in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (2016/679) (‘GDPR’) and EU member state national laws that implement or regulate the collection, processing and privacy of your personal data (together, ‘EU Data Protection Law’).
1.2 – This EU/UK/Canada privacy notice (‘EU/UK/Canada Privacy Notice’) which should be read in conjunction AOA’s Privacy Policy provides further information as required under EU Data Protection Law on how we handle or process the personal data we collect and who we may share it with.
1.3 – This Privacy Notice also provides information on your legal rights under EU Data Protection Law and how you can exercise them.
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How personal data is collected
2.1 – Because of the global nature of our organization and its network, AOA may hold and process personal data that is collected from programs, fellowships and partner organizations around the world, including within the EU/UK/EEA.
2.2 – This also means that if you are a member or individual contact of this network resident in the EU/UK/EEA, your personal data may be transferred from the EU/UK/EEA to AOA headquarters in the United States.
2.3 – US data privacy laws are currently not considered to meet the same legal standards of protection for personal data as set out under EU Data Protection Law. However, in order to safeguard personal data received from the EU/UK/EEA, we only allow such a transfer of personal data to the US or other third countries under an approved contract or another appropriate mechanism which is legally authorized under EU Data Protection Law.
2.4 – This is to make sure that the personal data that AOA receives and processes (so far as it relates to residents of the EU/UK/EEA) is properly safeguarded in accordance with similar legal standards of privacy you would enjoy under EU Data Protection Law.
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Direct Marketing
3.1 – If AOA provides direct marketing communications to individuals in the EU/UK/EEA regarding services and/or events which may be of interest, this will be done in accordance with EU Data Protection Law, and in particular where we contact individuals for direct marketing purposes by SMS, email, fax, social media and/or any other electronic communication channels, this will only be with the individual’s consent or in relation to similar services to services that the individual has purchased (or made direct enquiries about purchasing) from AOA before.
3.2 – Individuals are also free to object or withdraw consent to receive direct marketing from us at any time, by contacting us using the email address below.
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The lawful grounds on which we collect and process personal data
4.1 – We process your personal data for the above purposes, relying on one or more of the following lawful grounds under EU Data Protection Law:
(a) where you have freely provided your specific, informed and unambiguous consent for AOA to process your personal data for particular purposes
(b) where we agree to provide services to you, in order to set up and perform our contractual obligations to you and/or enforce our rights
(c) where we need to process and use your personal data in connection with our legitimate interests as a global network and being able to effectively manage and operate our organization in a consistent manner across all territories. We will always seek to pursue these legitimate interests in a way that does not unduly infringe on your legal rights and freedoms and, in particular, your right to privacy, and/or
(d) where we need to comply with a legal obligation or for the purpose of us being able to establish, exercise or defend legal claims.
4.2 – Please also note that some of the personal data we receive and that we process may include what is known as ‘sensitive’ or ‘special category’ personal data about you, for example, information regarding your gender, ethnic origin or political, philosophical and religious beliefs. If the AOA processes such sensitive or special category data we will only do this in specific situations where:
(a) you have provided this with your explicit consent for us to use it: or,
(b) there is a legal obligation on us to process such data in accordance with EU Data Protection Law
(c) it is needed to protect your vital interests (or those of someone else) such as in a medical emergency or,
(d) where you have clearly chosen to publicize such information or,
(e) where needed in connection with a legal claim that we have or may be subject to.
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Disclosing your personal data to third parties
5.1 – We may disclose your personal data to certain third party organizations who are processing data solely in accordance with our instructions (called ‘data processors’) such as companies and/or organizations that support our business and operations (for example providers of web or database hosting, IT support, payment providers, event organizers, agencies we use to conduct fraud checks or mail management service providers) as well as professionals we use such as lawyers, insurers, auditors or accountants. We only use those data processors who can guarantee to us that adequate safeguards are put in place by them to protect the personal data they process on our behalf.
5.2 – We may also disclose your personal data to third parties who make their own determination as to how they process your personal data and for what purpose(s) (called “data controllers”). The external third party data controllers identified above may handle your personal data in accordance with their own chosen procedures and you should check the relevant privacy policies of these companies or organizations to understand how they may use your personal data.
5.3 – Other than as described above, we will treat your personal data as private and will not routinely disclose it to third parties without you knowing about it. The exceptions are in relation to legal proceedings or where we are legally required to do so and cannot tell you (such as a criminal investigation). We always aim to ensure that your personal data is only used by third parties we deal with for lawful purposes and who observe the principles of EU Data Protection Law.
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How long we retain your personal data for
6.1 – AOA retains personal data identifying you for as long as necessary in the circumstances – for instance, as long you are a member of the AOA or have a relationship with one of our programs for a reasonable period to send you marketing or other materials where we have regular contact with you, or as may be needed to enforce or defend contract claims or as is required by applicable law.
6.2 – AOA has adopted a data retention policy for EU / UK residents (which we may make available on request) that sets out the different periods we may retain personal data for in respect of relevant purposes in accordance with our duties under EU Data Protection Law. The criteria we use for determining the relevant retention and disposal periods we adopt are based on the purpose for which we hold data and the reasonable expectations of those whose personal data we collect in these circumstances, taking into account various legislative requirements and guidance issued by relevant EU regulatory authorities.
6.3 – In accordance with the above retention policy, the personal data that we no longer need will be disposed of and/or anonymized so you can no longer be identified from it.
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Your personal data rights
7.1 – In accordance with your legal rights under EU Data Protection Law, you have a ‘subject access request’ right under which can request information about the personal data that we hold about you, what we use that personal data for and who it may be disclosed to as well as certain other information.
7.2 – Usually we will have one month to respond to a subject access request. However, we reserve the right to verify your identity and we may, in case of complex requests, require a further two months to respond. We may also charge for administrative time in dealing with any manifestly unreasonable or excessive requests. We may also require further information to locate the specific information you seek and certain legal exemptions under EU Data Protection Law may apply when responding to your subject access request.
7.3 – Under EU Data Protection Law. EU/EEA residents also have the following rights. which are exercisable by making a request to us in writing:
(a) that we correct personal data that we hold about you which is inaccurate or incomplete
(b) that we erase your personal data without undue delay if we no longer need to hold or process it
(c) to object to any automated processing (if applicable) that we carry out in relation to your personal data.
(d) to object to our use of your personal data for direct marketing
(e) to object and/or to restrict the use of your personal data for purpose other than those set out above unless we have a compelling legitimate reason, or
(f) that we transfer personal data to another party where the personal data has been collected with your consent or is being used to perform contract with you and is being processed by automated means.
7.4 – So we can fully comply, please note that these requests may also be forwarded on to third party data processors who are involved in the processing of your personal data on our behalf.
7.5 – If you would like to exercise any of the rights set out above, please contact us at the address below.
7.6 – If you make a request and are not satisfied with our response, or believe that we are illegally processing your personal data, you have the right to lodge a complaint to a supervisory authority including, without limitation, the EU Member State of his or her habitual residence, place of work or place of the alleged infringement.