PRIVACY NOTICES
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Overview
Keychange U.S. Inc., (registered nonprofit number in New York State DOS ID 6618470) takes your privacy very seriously. This notice explains how we hold and use personal information and your rights and options in relation to it.
Please note that we have an additional privacy notice that applies if you apply for and/or receive a grant from us. You can access the Grantholder Privacy Notice in the other drop down menu.
Keychange U.S. supports a wide variety of people; people who receive grants or advice and information from us, partners (organizations and individuals); supporters, and volunteers. To provide products, services, information and opportunities tailored to each person or organization, Keychange U.S. processes information about them (personal data). This helps to ensure that they are getting the best service possible from Keychange U.S. This also helps us, where appropriate, to ask for your support with the things we believe you care about the most.
Changes to this Privacy Notice
This Privacy Notice may change from time to time so it’s a good idea to come back and read through it again regularly. Where necessary, for example if there are significant changes, we may also notify you of the changes to this Privacy Notice by email where possible.
This Privacy Notice was last updated in May 2023
Data Controller
A Data Controller is a person or organization who decides why and how information about you (personal data) will be stored, shared and used.
For data collected, stored and processed by Keychange U.S., the data controller is Keychange U.S. c/o CoveyLaw, 20 Jay Street #316, Brooklyn, NY 11201.
Third Party Websites
Keychange U.S. is not responsible for the content and practices of third party websites where we have links from the Keychange U.S. website. This Privacy Notice does not cover those websites and we are not responsible for their privacy practices or content. They will have their own privacy policies and we urge you to review them if you choose to follow those hyperlinks. Links to other websites are often provided solely as reference points to information on topics that may be useful to our users.
How We Collect Personal Information
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect personal information in the following ways:
Directly from you, for example, by filling in forms on our website e.g. when you sign up on Mailchimp to receive Keychange U.S.’s newsletters, or offline (including taking part in our events), or communicating with us by phone, email or letter or when you meet with us.
Indirectly, via third parties, for example, information we receive from beneficiaries via the organizations we support. Sometimes they may ask for your consent to share this personal information with us, such as where we would like to include your personal information (including photographs) in case studies to publish on our websites or offline.
We may also receive information from analytics providers (such as Google), and contact, financial and transaction information from technical, payment and delivery services.
Depending on your settings and the relevant policies and terms of service, you might give us permission to access information about you from social media such as Instagram, Facebook, LinkedIn, Twitter, and TikTok.
If we have not done so already, we will notify you when we receive personal information about you from other sources and tell you how and why we intend to use that personal information.
When you visit our websites, we automatically collect some technical information from your computer or mobile device such as IP address, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms, and information about your visit to the website and your use of it.
We also collect cookies, see item 6 below for more information.
What Personal Data is Collected and Stored by Keychange U.S.
We collect, store and use the following kinds of personal information:
Identity data such as your name, username (and other profile data such as your preferences, social media profiles, feedback and survey responses)
Photographs, video and/ or audio recordings
Contact data such as your address, email and telephone numbers
Financial data such as bank account and payment details, and Gift Aid information
Transaction data, including details of payments and donations
Technical data such as your IP address when you browse our websites
Communication Preferences
Any other information you provide us as above (“3 How we collect and process personal information”).
Visitors to the Keychange U.S. website
When someone visits www.keychangeus.com we use Google Analytics to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the website. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect information which can identify you through our website, we will tell you about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Use of Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website.
A cookie is a small piece of data that is sent from our web server to your browser. It is stored on your hard drive. A cookie cannot read data off your hard disk or read cookie files created by other sites, and will not damage your system. If you would like to know more about cookies please visit www.aboutcookies.org.
Keychange U.S. is committed to delivering an informative and easy to use website. It therefore utilizes cookies to provide us with a better picture of how it is being visited and used. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
How to Delete or Disable Cookies
For details of how to delete or disable cookies, you can find general information at www.allaboutcookies.org and browser-specific information via the following links:
Internet Explorer: How to disable Cookies
Firefox: Enabling and disabling Cookies
Safari: Managing Cookies
Google Chrome: How do I turn off Cookies?
Opera: Security & privacy
How And Why Keychange U.S. Will Use Personal Information?
We will use your personal information for purposes specified in this Notice. This includes:
for “service administration purposes”, which means that Keychange U.S. may contact you for reasons related to the service you have signed up for (e.g. to provide you with reminders or to notify you that a particular service has been suspended for maintenance)
to provide you with information or support
to administer grants (as further explained in our Grantholder Privacy Notice)
to contact you about a submission you have made to the websites, including any content you have provided
to personalize the way Keychange U.S. content is presented to you
IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use, to help us improve the usability of the site and the relevance of the content on the site; and
to analyze and improve the services offered on Keychange U.S. websites e.g. to provide you with the most user-friendly navigation experience, and to administer our websites.
to enable us to review, develop and improve the products, services and special offers online
to occasionally carry out market research
to send you details of Keychange U.S.'s work, activities, promotions, products, services, special offers and rewards that we think will be of interest to you via our newsletter to which you have signed up via Mailchimp or if you consented to receive our newsletter at application stage. It’s up to you to decide whether or not you want to receive this information.
to process donations
to communicate with you in general and to manage relationships with our supporters and stakeholders
to audit and administer our accounts
to satisfy legal and regulatory obligations, and for the prevention of fraud or misuse of services
for the establishment, defense and/or enforcement of legal claims.
Where Keychange U.S. proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for your use other than as listed above.
When And How will Keychange U.S. Contact Me?
Keychange U.S. may contact you for a number of different purposes using the contact details you have provided. The basis on which we do so differs depending on the purpose of the communication, and specifically whether it is a marketing communication or not.
a. Marketing communications
We may use your contact details to provide you with information about our work and campaigns which we consider may be of interest to you. Where we do so by email, we will obtain your consent to do so (which can be withdrawn) for example, if you sign up to receive newsletters from our website. Where we do so by post, we are doing so on the basis of our legitimate interests, unless you opt-out.
Generally, we send the following types of marketing communications:
Updates about our work or the work of partner organizations and projects that we support
Campaigns
Information about events. Note that if you sign up to an event we will then send you administrative communications about the event. On occasion we may also send you a reminder about the same event in future years in case you want to participate in it again
You control how we use your personal information for these purposes and can update your preferences at any time – please contact us at info@keychangeus.com if you would like to do so.
If you opt out of these communications, we may retain some appropriate information to enable us to comply with the request not to be contacted in the future.
b. Administrative and other communications
We will communicate with you using the contact details you have provided for essential administrative and other non-marketing purposes, such as to respond to queries, administer a donation or provide you with services or information you have requested, contact you about an event you are attending, for research purposes or to survey you about Keychange U.S.’s services (participation is always voluntary).
Note that we may still need to communicate with you for these purposes even where you have opted-out of receiving marketing communications from us.
Who Keychange U.S. Shares Personal Data With
Generally, we will only use your personal information within Keychange U.S. and share with third parties to the extent required to achieve the purposes set out in this Privacy Notice. We require these third parties to respect and safeguard your personal information.
Third parties with whom we share the data so that they may process it on our behalf, and act only in accordance with our instructions may include:
suppliers and subcontractors for the performance of any contract we have with them – for example for IT services such as website hosting
advisers who help the grant selection process
insurers and professional service providers such as accountants and lawyers
financial companies that collect or process donations on our behalf, and external fundraising platforms
We also reserve the right to disclose your information to third parties for their own purposes in some cases. For example:
funding partners including TDP, public and private funders or sponsors, for the purpose of selecting and supporting grantees
if we sell or buy all or part of a business, in which case we may disclose it to the potential seller or buyer
if we are under a legal or regulatory duty to do so
to protect the rights, property and/ or safety of the charity, its personnel, supporters, users or others (including you)
regulatory authorities, such as the IRS.
Protecting Your Personal Information
We take appropriate and proportionate measures to keep your personal information secure and to prevent the loss, destruction or misuse of it. For example, information is stored on a secure server and can only be accessed by authorized personnel.
Please note that the transmission of information via the internet is never completely secure, and although we do our best to protect it, we cannot guarantee the security of personal information transmitted over the internet.
The personal information we collect is stored at a destination within the U.S.
How Long Personal Information is Kept by Keychange U.S.
Keychange U.S. will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements. This length of time may vary depending on these purposes. For example:
If the data is necessary for the performance of a contract, we will retain it while performance under that contract remains active, and for a period thereafter in which that data may still be relevant to dispute resolution, enforcement of rights under the contract, accountancy purposes or where additional connected contracts are likely to arise.
In certain cases we may be legally obliged to hold data for a certain period of time, or to delete the data at a certain time, including in accordance with the exercise of your rights as data subject as explained in this Notice.
If you would like further information, please contact us (see details below).
In some circumstances we may anonymise your personal data (so it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Our legal basis for collecting and using personal information
The law on data protection sets out several different reasons for which a company may collect and process personal data. The following are relevant to the purposes set out above:
a. Consent
In specific situations, we can collect and process your data with your consent, for example to receive marketing emails and text messages. This consent can be withdrawn
b. Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations, for example, for a research company to evaluate one of Keychange U.S.'s programs managed and funded by Keychange U.S. with additional funding from public funding bodies.
c. Legal compliance
If the law requires us to, we may need to collect and process your data for example, to share your personal information with the IRS to process donations.
In certain circumstances we may need your personal data where it is in your / somebody else’s vital interests for example, in the case of a medical emergency suffered at an event
d. Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably expected as part of running our business and which does not materially impact your rights, freedom or interests.
Where we rely on legitimate interests, depending on the activity, those might be Keychange U.S.’s interests or those of a partner organization. These legitimate interests, ultimately, are in the running of a commercial entity in pursuit of our charitable objectives, and include the following:
Charity governance, including delivery of our purposes, statutory and financial reporting and other regulatory compliance
Administration and operational management, including responding to solicited enquiries, providing information, research, donor due diligence, events management, the administration of our projects and employment and recruitment requirements
Fundraising, marketing and campaigning, including administering campaigns and donations.
Providing our services, and this can include your interests, such as when you have requested information or services from us, or the interests of beneficiaries.
We will not use your personal data for direct marketing purposes unless you have provided your consent to us, or to a third party via which we have received the data. You have the right to ask us not to process your personal data for these purposes.
Your Privacy Rights
The European General Data Protection Regulation (GDPR) provides you with rights to:
request from us confirmation of whether or not your personal data is being processed and where that is the case, confirmation of the information set out in this Notice;
request from us a copy of your data that is undergoing processing, including, in relation to data provided to us by you, and which is processed by automatic means pursuant to a contract with you, or pursuant to your consent, a right to request that data in a structured, commonly used and machine readable format;
request that we rectify or complete your personal data, where it is inaccurate or incomplete for the purposes of our processing of the data;
request that we erase your personal data in the following circumstances:
the personal data is no longer necessary in relation to the purposes for which it is processed;
you withdraw consent and there is no other legal ground for the processing;
you successfully object to the processing pursuant to your right of objection explained below;
the personal data has been unlawfully processed;
the erasure is necessary for compliance with a relevant legal obligation that applies to us;
request that we restrict the processing of your personal data in the following circumstances:
you contest the accuracy of the personal data, for a period enabling us to verify the same;
the processing is unlawful, but you request restriction rather than erasure;
we no longer need the data, but it is required by you in respect of legal claims;
you have objected to the processing, until such that that we verify that there are legitimate purposes that justify such processing;
object to any processing that is based on our, or a third party’s legitimate interests, upon which event we shall suspend processing until we demonstrate legitimate purposes that justify that processing. We may at all times continue to use data for the purpose of establishment, exercise or defense of legal claims;
withdraw your consent for future processing (where the processing is based on that consent);
We will comply with any valid request for information under the rights explained above within one month, though we may tell you that this period is to be extended by a further two months where necessary, taking into account the complexity and number of the requests. This will normally be provided free of charge. If the request is manifestly unfounded, excessive or repetitive we may charge a reasonable fee or refuse to action the request.
The provision of personal data to us is not a statutory requirement. The provision of data may be a condition of entering into a contract with us, and in such cases we will let you know. We cannot carry out our obligations under our contracts with clients without the necessary data.
Further Information
If you have any questions which you feel have not been covered by this Privacy Notice, please do not hesitate to email us or write to:
Marie Fol
Keychange Project Lead
Keychange U.S. Liaison
marie@keychange.eu
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GRANT HOLDER PRIVACY NOTICE (Privacy notice that applies if you apply for and/or receive a grant from Keychange U.S.)
This Notice explains how Keychange U.S. Inc., (registered nonprofit number in New York State DOS ID 6618470, uses personal information to administer grants.
Changes To This Notice
This Notice may change from time to time. We will notify you of significant changes by contacting you directly via the email provided in your application.
This Notice was last updated October 2022.
What Personal Information Will Keychange U.S. Collect And Process About Me?
Personal information Keychange U.S. collects in the course of assessing and administering its grants is primarily obtained directly from the grant applicant during the application process (and therefore indirectly from the individual). Mainly, this will be information about an individual (either the applicant or their representative, such as their manager,) who is a point of contact for the grant/ prospective grant.
Keychange U.S. collects, stores and use the following kinds of personal information:
Identity information such as your name, username, social media account, and identity details like pronouns and gender (and other profile data such as your preferences, feedback, and survey responses).
Contact data such as your address, email, and telephone number(s).
Financial data such as bank account and payment details necessary to pay you.
Transaction data, including details of payment and donations.
Diversity data which is used for internal monitoring purposes only (and does not affect the outcome of application or funding decisions).
Technical data such as your IP address when you visit our websites.
Any other information you provide to us in the course of the grant application or throughout the grant period or thereafter.
How and Why Will Keychange U.S. Use My Personal Information?
Keychange U.S. will use your personal information for a number of purposes including:
To administer an account on our grants application portal.
To process and assess grant applications, including contacting you to discuss the application and any questions that may arise.
To administer grants and for the purpose of the grant relationship, to include ongoing contact regarding the relationship, payment, monitoring and evaluation, and reporting purposes (including audits).
To promote Keychange U.S. grant-funded work.
To occasionally carry out market research.
To send details of Keychange U.S. opportunities, relevant events, and news that we think will be of interest to you. It’s up to you to decide whether you want to receive this information, which is covered by our separate, General Privacy Notice (Pg 6-16).
To satisfy legal and regulatory obligations.
For the prevention of fraud.
For the establishment, defense, and/or enforcement of legal claims.
Collaborative working and networking
Keychange U.S. is a network-building organization, and regularly hosts meetings between grant recipients for the purpose of information sharing. We may share the named grant recipient’s contact details with other grant recipients and partner organizations to benefit the grantees, and when we deem this to be in their legitimate interests.
Will Keychange U.S. Share My Personal Information With Anyone Else?
Generally, your personal information will only be used within Keychange U.S. and shared with third-party entities to the extent required to achieve the purposes set out in this Notice. We require third parties to respect and safeguard your personal information.
Keychange U.S. may share data with the following third parties to act only in accordance with our instructions. This list is illustrative and may change:
Relevant existing and future funding and program partners.
Consultants
Suppliers and subcontractors for the performance of any contract we have with them – for example, mentors, trainers, and IT services, such as website hosting.
Advisors and experts who help the grant selection process.
Professional service providers such as accountants, lawyers, insurance, and HR experts.
Financial companies that collect or process donations on our behalf, and external fundraising or payment platforms, as necessary for operations.
Our founding donors, TuneCore and Believe, with whom we share key statistics relating to demand, grantee numbers, and overall diversity of grantees.
We also share grantee names and data with relevant Keychange U.S. team members who may reach out to grantees to offer additional support during the Talent Development Program.
Keychange U.S. reserves the right to disclose your information to third parties for their own purposes in limited cases. For example:
If we sell or buy all or part of a business, in which case we may disclose it to a potential seller or buyer.
If we are under the legal or regulatory duty to do so, f.ex. by the IRS or other federal government agencies.
To protect the rights, property, and/or safety of the nonprofit, its personnel, supporters, users, and others (including you).
International Data Transfers
Generally, the personal information we collect is handled at a destination within the U.S. by Keychange U.S. and the Keychange Core Partners in Europe for program consistency and oversight over funding spent towards the Keychange U.S. Talent Development Program.
How Long Will Keychange U.S. Keep My Personal Information?
Keychange U.S. will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements. The length of time may vary depending on these purposes. For example:
If the data is necessary for the performance of a contract, it will be retained while that contract remains active, and for a period thereafter in which that data may still be relevant for dispute resolution, enforcement of rights under the contract, accounting purposes, or where additional connected contracts are likely to arise.
In certain cases, we may be legally obligated to hold data for a certain period of time or to delete the data at a certain time, including in accordance with the exercise of your rights as data subject as explained in this Notice.
If you would like further information, please contact us (see details below).
In some circumstances, we may anonymize your personal data (so it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Our legal basis for collecting and using personal information.
The legal bases for the processing of personal information set out in this Notice are:
Where there is a contract and the use is necessary for the performance of the contract or to take steps at your request prior to entering into it. For example, a contract with a research company to evaluate one of Keychange U.S.’s funding programs.
Where there is a legal or regulatory obligation, for example, to share your personal information with the IRS for grant management or related fundraising purposes.
Where it is necessary for Keychange U.S. or the “legitimate interests” of other parties and this is not overridden by your interests or rights. Keychange U.S.’s legitimate interests will primarily be the legitimate pursuit of its grant-making activities as a charitable entity, and associated work.
Your Privacy Rights
You have the following rights:
To ask for the personal information we hold and for a copy of it.
To withdraw consent.
To object to processing (use) – you have the right to object where we are (i) relying on the legal basis of your legitimate interests (ii) using your personal information to send direct marketing or (iii) using it for statistical purposes.
To erasure – in some cases, you can ask us to delete your personal information from our records (or anonymize it).
To restrict processing – instead of deletion, you may ask us to restrict our use of personal information if there is a disagreement about its accuracy or legitimate usage.
To rectify – if you believe our records concerning you are inaccurate, you can ask us to update them. You can ask us to check the personal information we hold about you if you are unsure.
To ‘data portability’ – this means that, where we are processing your personal information using automated means on the basis of consent, or to perform a contract, you can ask us to transfer it to you or another service provider in a usable format.
Note that we may ask you for proof of ID or further information.
These rights only apply in limited circumstances.
Contact us (including complaints)
To exercise your rights, or if you have any questions or concerns about this Privacy Notice or use of your personal information, please let us know by contacting us in one of the following ways:
POINT OF CONTACT INFORMATION HERE:
Joe Frankland
Keychange U.S. Director
info@keychangeus.com
You are entitled to make a complaint at any time to the POC.
We are always grateful for the opportunity to resolve your concerns before you feel the need to speak to an outside entity.