2. Personal Information
3. Collection, Use and Disclosure of Personal Information
4. Collection, Use and Disclosure of Usage and Aggregate Data
5. Consent and Withdrawal
6. Data Retention
7. Control of Your Data
8. Governing Law and Your Rights
9. Job Applicants’ Personal Data/Information
10. Contacting Divine Renovation
References to Divine Renovation in this privacy notice include each of the following entities:
Personal Information shall include personal information as such term is defined in the (i) Personal Information Protection Electronic Documents Act; (ii) Privacy Act of 1988 (Australia); (iii) the Privacy Act (New Zealand) and (iv) personal data as that term is defined in the General Data Protection Regulation (EU 2016/679), and/or the UK GDPR which is the General Data Protection Regulation as implemented into the law of the United Kingdom (“UKGDPR”); provided that for the purposes of this Policy, Personal Information shall not include Information about Divine Renovation employees in such employees’ capacity as employees of Divine Renovation.
Note that in this Data Privacy Notice, references to the GDPR are to the General Data Protection Regulation (EU 2016/ 679) and/or the UKGDPR as applicable.
It is the Policy of Divine Renovation to keep any information gathered through the use of our systems secure. As such, your information is not disclosed or shared to unauthorized third parties except as allowed by Canadian law or the relevant laws in the jurisdiction where you reside.
Divine Renovation collects Information that personally identifies you, such as:
• Identity Data (name, title, username)
• Contact data (address, mobile telephone number, e-mail addresses, contact preferences)
• Structure Data (parish name, diocese name, pastor/priest)
• Profile Data (feedback and survey responses)
• Usage and Aggregate Data (see Section 4. Collection, Use and Disclosure of Usage and Aggregate Data)
• Event Information (attendance, photography if at events)
• Donation Information (donation amounts, donation methods)
• Philanthropic Profile Information (philanthropic history, career history, relationships, relevant interests)
• Correspondence between you and us
• Financial payment details
…and other information you provide to Divine Renovation or information on the Divine Renovation profile or account. Personal Information may be collected in a number of ways, including in-person, over the phone, by mail, over the internet, and from third parties that you have authorized to disclose Personal Information to us.
We collect information when you opt to share your information with us by signing up for accounts, donating, registering for events, subscribing to services or communications, entering competitions, and/or through their choice to submit surveys or feedback.
We make every reasonable effort to keep your Personal Information as accurate, complete and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your Personal Information in our records.
Certain types of personal data are sensitive and need more protection—for example, information about religious beliefs or health information. We only process these types of personal data about you if the law allows us to do so. One example is information shared by you to identify your parish or diocese. Another example is your information about a dietary request and access to Information for our events.
Divine Renovation reserves the right to use your contact information for the purposes of communications regarding any aspect of your account or corresponding services and products. You will have the option to opt-in or opt-out of optional communications (e.g. marketing, press, events), while mandatory communications (e.g. administrative messages about events that you intend to attend) will go out to all individuals who it is necessary for us to contact in connection with these administrative or other purposes
We will only send promotional materials to the e-mail address where you have requested to receive it (for example, if you have signed up for our newsletters). We may also send promotional materials via e-mail to your publicly available work e-mail address (if you work at a company or other incorporated body) if we feel that you may be interested in hearing more about Divine Renovation.
Divine Renovation uses and discloses Personal Information for the purposes for which it was obtained by Divine Renovation. For example, Divine Renovation may collect, use and disclose Personal Information for the following purposes:
• providing you with the services and information you have requested (for example, event registration or newsletters)
• corresponding with you to:
o send updates about our activities and upcoming offers
o process donations (including claiming Gift Aid were possible)
o develop resources (for example, webinars and courses)
o support volunteers
o refer you to services offered by the Divine Renovation group of charities
o conduct fundraising activities to support Divine Renovation
• operating and administering all of the charities that form part of Divine Renovation
• conducting research for fundraising purposes that includes desk research into current and potential supporters and wealth screening
• administering our website (including ensuring that it has adequate security in place)
• handling any complaints or concerns which may arise (including any legal disputes)
For Information about job applicants and how we use their personal data, see Job Applicants’ Personal Data/Information.
Divine Renovation will never rent or sell the Personal Information it collects.
If you sign up for an event that Divine Renovation is hosting with a partner, Divine Renovation may share the necessary information with that third-party host to allow that third party to provide services to you in connection with the event.
We may use your information to aid in our fundraising efforts. Fundraising efforts include in-house research and the occasional use of specialist agencies. Research of this nature is used determine capacity or affinity to support Divine Renovation and its global efforts. In some cases, we may use your information to help identify connections between our constituents to help reach new supporters or to aid in service delivery. We may review other information about you that is available to the public through internet searches, social networks, such as LinkedIn, subscription services, news archives or public databases (e.g. Companies House, the electoral, political and property registers), such as information about leadership roles, investments, published biographic information, employment and earnings, philanthropic interests, networks, giving history, motivations and relevant media.
Divine Renovation may also disclose Personal Information to third parties, where required by law or upon demonstrated lawful authority. The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose your Personal Information to authorities. Only the Information specifically requested is disclosed, and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so.
Your Personal Information may be disclosed in situations where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights or to investigate suspicion of unlawful activities. We may release certain Personal Information when we believe that such release is reasonably necessary to protect the rights, property and safety of ourselves and others.
Divine Renovation uses third-party service providers to host Information. These third-party service providers may have access to Personal Information as an incidental result of the services provided by them to Divine Renovation, but the access of such third parties to this Information is strictly controlled in accordance with the safeguards detailed below.
In addition to Personal Information, Divine Renovation collects usage information from users of our services. The purpose of this collection is to understand how individuals access and use our services, to analyze trends, to administer Divine Renovation’s services and products, and/or to troubleshoot, enhance, and improve Divine Renovation’s services.
Usage information and data could include but is not limited to your device type, device identifier, IP address, browser type, operating system, duration of use, number of messages sent or received, and times at which the application was accessed and used. In addition, Divine Renovation will collect aggregate data about a group or category of services or individuals.
We do not respond to browser do-not-track signals (DNT) because we do not track our users over time or across third-party websites.
Divine Renovation maintains the right to inform you about any change that may affect Information collected or stored.
If required to comply with a court order or governmental regulatory requirement to disclose Information in connection with legal proceedings, we will do so and will make every effort to notify the relevant parties about the proceedings.
Divine Renovation is not anticipating any changes in corporate status as an international not-for-profit; however, as we grow and develop, that may change. You understand and agree that we may use your Personal Information and disclose Personal Information to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction.These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing Personal Information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your Personal Information for substantially the same purposes as those set out in this Policy. In the event the transaction does not go through, we will require, by contract, the other party or parties to the transaction not to use or disclose your Personal Information in any manner whatsoever for any purpose and to return or destroy such Personal Information. Personal Information that is collected online remains subject to applicable legislation and corporate Policy.
Generally, we do not rely on consent as a legal basis for processing your personal data other than when we collect Special Categories of Data or in relation to sending direct marketing communications to you via e-mail or text message. You may withdraw your consent at any time; however, be aware that withdrawal of consent may result in our inability to offer you our services. For example, Divine Renovation may have to cancel your tickets to an event or service if you ask to be removed from our systems. However, this will only apply where it is impossible for us to provide or give access to that service without consent. If this is the case, Divine Renovation will notify you of this at that time.
Divine Renovation processes and stores Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Divine Renovation reserves the right to reject, suspend, alter, remove or delete data if it breaches the terms and conditions in our internal governing policies or where it is necessary to protect us or others where we have reasonable grounds for believing that a criminal act has been committed, or if required to do so by law.
Due to the international nature of Divine Renovation, your information may be processed on servers located outside the country in which you live. Where your Personal Information is transferred outside the country of origin to a country which does not offer a similar level of protection to that offered in the country of origin, Divine Renovation will take all reasonable steps necessary to ensure that the recipient appropriately protects your personal data in accordance with applicable law by, for instance, entering into standard contracts that supervisory authorities have approved. Although Divine Renovation makes efforts to limit international data transfers, some transfers may be necessary depending on the services we provide. The different entities that make up Divine Renovation may also share personal data between them, which will involve international data transfers. Divine Renovation applies the privacy protections listed in this policy and data protection safeguards to all Personal Information within our care, regardless of origin.
Divine Renovation has appropriate security measures in place to protect Personal Information it processes to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction.
Divine Renovation has appointed a Designated Privacy Contact who acts as Chief Privacy and Security Officer (CPSO) responsible for information system monitoring and information security policy and procedure management. The CPSO is responsible for compliance with Divine Renovation’s privacy program, including:
You may access your Personal Information by accessing your account and, should you require assistance, by contacting our CPSO. Our CPSO’s contact information can be found below.
Safeguard measures to ensure authorized access include: the use of a username and a password for authentication. You must keep your password and username safe and make sure that any person who has access to view such private Information is permitted to do so. You must contact Divine Renovation immediately if you believe your password has been misused, compromised or misused.
Divine Renovation stores Personal Information in the United States with Salesforce. Salesforce is considered compliant with ISO 27001, ISO 27017 and ISO 27018 in addition to GDPR and other standards. Please see Salesforce’s Terms of Service for details on the company’s information and security practices.
Divine Renovation stores Personal Information, such as your name and e-mail address, with MailChimp who processes data in the United States and other parts of the world. Please see MailChimp’s Terms of Service for details on the company’s information and security practices.
For donations made to Divine Renovation Ministry in Canada, Divine Renovation stores Personal Information in the United States with Donorbox. Please see Donorbox’s Terms of Service for details on the company’s information and security practices.
Divine Renovation uses Xero to process accounting transactions. Personal Information such as your name, e-mail, parish/diocese, and/or address may be stored with Xero at Amazon Web Services regions in the United States. Xero is certified compliant with ISO/IEC 27001:2013. Please see Xero’s Term of Service for details on the company’s information and security practices.
Divine Renovation stores Personal Information in the United States with Microsoft. Microsoft is certified compliant with ISO 27017, ISO 27018, GDPR, and many others. Please see Microsoft’s Terms of Service for details on the company’s information and security practices.
Divine Renovation strives to make all its services compliant with the GDPR. Divine Renovation reminds EU and UK residents of their rights. These include the right:
We handle personal data about those who apply to work with us (applicants) slightly differently than we have discussed above.
When an applicant applies to work with Divine Renovation, we will collect and use the applicant’s personal data for the purposes of evaluating their application as part of our recruitment process.
We will collect the following types of personal data:
We will use the personal data we collect about the applicant to:
It is in our legitimate interests to decide whether to appoint an applicant to the role since it would be beneficial to Divine Renovation to appoint qualified and enthusiastic individuals.
Please note that if an applicant fails to provide us with the relevant details that we request, we will not be able to process their application.
If an applicant is successful in their application, we will transfer the personal data collected as part of the recruitment process to their employment record. We will also provide them with an employee-specific privacy notice.
If an applicant is unsuccessful in their application, we will usually retain the personal data collected about the applicant for six months following the communication of our decision to the applicant, unless we are legally obliged to keep it for a longer period of time.
You may contact our CPSO to make inquiries on our privacy practices or the accuracy of their personally identifiable Information and request the update, correction, or deletion of such Information or account should they wish to do so. Any query, comments or concerns can be sent to us by e-mail at pri[email protected] or by mail at the following addresses:
Divine Renovation Ministry
PO BOX 51069 RPO Rockingham Ridge
B3M 4R8 Canada
5-7 Cromwell Road,
London, SW7 2HR
Australia and New Zealand
4 Canterbury Ct
United States of America
847 E. Bethel School Rd.
Coppell, TX 75019
Deutschland, Österreich & Schweiz
Divine Renovation Deutschland e.V.
Langemarckstrasse 56a, 53227 Bonn, Deutschland