ROTARACT D9212 PRIVACY POLICY

Introduction
Rotaract District 9212 of Rotary International (D9212) (individually or collectively, “Rotary” or “we”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). Maintaining protection of the data entrusted to our care by our constituents is of the utmost importance to D9212.
This Policy describesthe types of data we may collect from you or that you may provide and describes our policies and practices for collecting, using, protecting, and disclosing that data.
This Policy may change from time to time (see Changes to Our Privacy Policy section), so check the Policy periodically for the most current version. If you have any questions about the meaning or interpretation of this Policy, the English-language version of this Policy is the official text.

Your Rights in relation to your data
Data protection legislation gives you, the data subject, various rights in relation to your personal data that we hold and process. These rights are exercisable without charge, and we are subject to specific time limits in terms of how quickly we must respond to you. Those rights are, in the main, set out in Section 26 of the Data Protection Act. They are as follows:

• the right to be informed of the use to which their personal data is to be put;
• the right to access their personal data in custody of data controller or data processor;
• the right to object to the processing of all or part of their personal data;
• the right to correction of false or misleading data; and
• the right to deletion of false or misleading data about them.

Full details of these rights can be found in the Data Protection Act or by reference to guidance produced by the Office of the Data Protection Commissioner (ODPC).
In the event that you wish to exercise any of these rights you may do so as provided for in the section “Accessing and Correcting Your Personal Data” below.

Data We Collect About You
In general, we collect several types of personal data, depending on the circumstances, that can be used to identify you (“Personal Data”), including your:

• Name
• Postal address
• Email address
• Telephone number
• Bank account, card details, mobile payment details, or other financial details;
• IP address, the browser you use, your operating system
• Equipment used to access our Website and usage details
• Account details, such as username, login details

Depending on the type of interaction that you have with D9212, we may also collect your:

• Gender
• Birth year
• Marital status
• Occupation
• Photographs/images, Government ID/Passport numbers (or some other government-issued identification number)
• Membership type and club in Rotary
• Education level
• Field of study
• Educational institution
• Current professional status
• Work experience level
• Skills
• Past experience
• Company name
• Company website
• Company location

How We Collect Your Data

We collect Personal Data from:

• Users of our Website
• Members of Rotary and Rotaract clubs
• People who attend Rotary events
• People who participate in Rotary’s programs

We collect this data:

• Directly when you provide it to us through any interaction offline or in person.
• From our websites www.rotary9212.org and www.rotaractdistrict9212.org (our “Websites”)
• From other Rotary websites that link to this Policy
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy
• Automatically, as you navigate through the Website (data collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies)
• When you sign up on or use the D9212 job board at https://jobs.rotaractdistrict9212.org or
  https://rotary9212.org/jobs
• When you become a member of a Rotary club or Rotaract club
• When you use our services
• When you participate in our programs or sign up for and/or attend any events that we host
• From third parties we contract with to provide services on our behalf, such as event organizers, travel service providers, payment processing services, email marketing services, and software providers; these service providers may change, or new service providers may be added without notice to you
• When you interact with us in another way, for example, contacting us with an inquiry.
• From publicly available resources.

Data You Provide to Us
We collect data you provide when you interact with D9212, either through our Websites or any interaction offline or in person. That data includes:

• Personal data that you provide by making an inquiry or joining as a member of a Rotary or Rotaract club; this includes data provided when registering to Rotary.org through My Rotary.
• Personal data you provide when participating in services available on our Websites.
• Personal data you provide when you enter a contest or promotion sponsored by us.
• Personal data you provide when you report a problem with our Websites.
• Records and copies of your correspondence (including email, social media posts, and other electronic messages), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your registration to attend and/or participate in D9212 events.
• Personal data you provide when making a donation or payment.
• Biographical or other data you provide to us, your Rotary or Rotaract Club, or D9212 (for example, if you choose to put your name forth as a candidate for an office in Rotary International, a Rotary club or D9212)
• Details of transactions made through our Website and details of the fulfillment of your orders (you may be required to provide financial personal data before placing an order through our Website)
• Your search queries on our Website.

Features that are developed in the future may result in the collection of additional new personal data.

You also may provide data to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Content”). Your User Content is posted on the Website and transmitted to others at your own risk. We limit access to certain pages and you may set certain privacy settings for this data from your account profile. However, we cannot control the actions of other Website users with whom you may choose to share your User Content.

Usage Details, IP Addresses, Cookies, and Other Technologies
As you navigate through and interact with our Website, we may automatically collect certain data about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

When you are not signed in to your D9212 account, the data collected in this way is anonymous. It is aggregated into statistical data to help us improve our Website and to deliver a better and more personalized service by enabling us to:

• Estimate our audience size, browser statistics, popularity of content, and usage patterns.
• Speed up your searches.
• Recognize you when you return to our Website.

We use cookies (or browser cookies) for this automatic data collection. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse
cookies, our system will issue cookies when you direct your browser to our Website.

When you are signed in to your D9212 account, we collect usage data that is tied to your individual
account. This data is collected to improve site functionality and to tailor site behavior and content to
you, and we process this personal data in accordance with this Policy.

Third-party Advertiser Use of Cookies and Other Tracking Technologies
Some advertisements and offers on our Website may be served by third-party advertisers, ad networks, and ad servers. Additionally, some of the applications accessible from, or on, our Website may be owned by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect data about our users. We do not control these third party tracking technologies or how they may be used. If you have any questions about an advertisement or offer on our Website, you should contact the responsible advertiser directly.

How We Use Your Personal Data
We use data that we collect about you or that you provide to us, including any personal data:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To offer and fulfill our core business purposes, which include:
  • Fulfilling Rotary’s obligation to Rotarians, Rotaractors, and other individuals
  • Financial processing
  • Supporting The Rotary Foundation, including fundraising efforts
  • Facilitating conference and special event planning.
  • Communicating key organizational messages through Rotary publications and other
    materials.
  • Supporting the programs and membership of Rotary.
  • Complying with any legal obligations.
  • Preserving D9212’s legacy by building and maintaining accurate archives that effectively
    document D9212 and Rotary’s history.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website.
• To store information about your preferences, allowing us to customize our Website according to your individual interests.
• To help us develop and test updates to this Website and other Rotary applications that support D9212 and Rotary’s core business purposes.
• In any other way we may describe when you provide the personal data.
• For any other purpose where we have your consent. If you are signed up on Kazi-Connect, We may use and analyse your information for the following purposes:
  • Verifying your identity information through publicly available and/or restricted government and Rotary network databases.
  • Processing your request on the platform such as role-based navigation and account editing.
  • For job seekers, to provide aggregated data (which do not contain any information which may identify you as an individual) to employers to enhance the hiring process.
  • Responding to any of your queries or concerns.
  • Keeping you informed generally about changes in platform policy or sending you personalized notifications.
  • To understand how you use our platform for purposes of developing or improving the platform.
  • Administer our platforms/website.

Disclosure of Your Personal Data
We may disclose aggregated data about our users, and data that cannot be used to identify any individual, without restriction.
We may disclose personal data that we collect or you provide as described in this Policy in order to perform our services for you, to comply with our contractual obligations to you, to comply with our legal or regulatory obligations to you, or to comply with any contractual, legal or regulatory obligations that we are subject to. These may include:

• To the Rotary club or Rotaract club in which you are a member (if applicable) or to RI.
• To Rotarians and Rotaractors in D9212 (if you are a District Leadership Team member)
• To Job seekers who need to find out more about the hiring organization (if signed up as an
  employer on Kazi-Connect)
• To Employers who need to directly contact you when shortlisted (if signed up as a job seeker on Kazi-Connect)
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them, including:
  • Travel service providers, such as airlines, hotels, ground transport, and travel agencies
  • Companies that produce, publish, and/or ship Rotary publications and Rotary branded
    goods and other merchandise.
  • Payment processing vendors.
  • Financial institutions and fiscal agents when processing financial transactions, such as expense reimbursements.
  • Software and applications used for administrative functions such as providing online forms/surveys/applications, newsletter services, online learning, webinar/teleconference services, electronic voting.
  • Cloud-based databases used for administrative functions.
  • D9212 conference committees and other event organizers and vendors.
  • Email distribution services
• To third parties to promote Rotary or for the third party to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal data confidential and use it only for the purposes for which we disclose it to them.
  • If you do not want us to share your personal data (even when anonymized) with unaffiliated or non-agent third parties for advertising or promotional purposes, you can send an email stating your request to tech@rotaractdistrict9212.org
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the data.
• With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or
  regulatory request.
• If disclosure is necessary or appropriate to protect the rights, property, or safety of Rotary, Rotarians, Rotary clubs, D9212, or others. This includes exchanging personal data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• When disclosing your personal data, we will ensure at all times that those with whom it is disclosed process it in an appropriate manner and take all necessary measures in order to protect it. In doing so we impose contractual obligations on all providers of services to ensure that your personal data is kept secure. We will only ever allow others to handle your personal data if we are satisfied that the measures which they take to protect that personal data are satisfactory.

Accessing and Correcting Your Personal Data
You may access and correct your data by Emailing tech@rotaractdistrict9212.org to request access to, correct, or delete any personal data that you have provided. We may choose not to accommodate
a request to change or delete data if we believe the change or deletion would violate any law or legal requirement or cause the data to be incorrect.
If you delete your User Content from the Website, copies of your User Content may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper
access and use of data provided on our Website, including User Content, is governed by our Terms of
Use.

Children Under the Age of 18
Our Website is not intended for children under 18 years. We do not knowingly collect personal data from children under 18 without parental consent. No one under age 18 may provide any personal data to or on our Website.
If you are under 18, do not:

• Use or provide any personal data on our Website or on or through any of its features.
• Register on our Website, make any purchases through our Website.
• Use any of the interactive or public comment features of our Website, or
• Provide any personal data about yourself to us, including your name, address, telephone
  number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal data from a child under 18 without verification of parental consent, we will delete that personal data. If you believe we might have any personal data from or about a child under 18, please contact us at tech@rotaractdistrict9212.org.

How Long We Retain Your Personal Data
D9212 retains your personal data for as long as necessary in the circumstances — for instance:

• As long you are a member of a Rotary or Rotaract club or have a relationship with our District.
• For a reasonable period to send you information, program information, and marketing materials where you have registered for a conference or other event or we have regular contact with you, or
• As may be needed to enforce or defend contract claims or as is required by applicable law.

Personal data that is processed by us will not be retained for any longer than is necessary for that processing, or for purposes relating to or arising from that processing. Please note, however, that different periods for keeping your personal data will apply depending upon the type of data being retained and the purpose of its retention.
We will delete and/or anonymize any personal data which it is no longer necessary for us to retain.

Data Security
We have implemented technical and operational measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. Additionally:

• When developing new or enhancing existing systems and processes, D9212 implements
  appropriate data protection throughout its data processing operations.
• All personal data you provide to us is stored on password-protected databases on our secure servers behind firewalls and we use Secure Sockets Layer (SSL) to ensure that the transmission of sensitive data for payments and contributions is encrypted and appropriately safeguarded.
• Employees are trained on the importance of data security and focus specifically on practices for protecting against unauthorized disclosure of personal data.
• We have a documented incident response plan for promptly acting upon events that violate
  D9212’s security or privacy policies, should they occur, in compliance with the relevant laws and regulations.

The safety and security of your personal data also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Passwords registered with our Website are encrypted to ensure protection against unauthorized access to your personal data.

Unfortunately, the transmission of personal data via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website or over any public network. Any transmission of personal data is at your own risk. Without prejudice to any mandatory legal obligations to which we may be subject, we are
not responsible for circumvention of any privacy settings or security measures on our Website.

Changes to Our Privacy Policy
D9212 may change, add, modify or remove portions of this Policy at any time, which shall become effective immediately upon posting on this page. The date the Policy was last revised is identified at the bottom of the policy. It is your responsibility to review this Policy for any changes. By continuing to use our Website, maintain your membership in our clubs, use our services, or participate in our programs, you agree to any changes in the Policy

Contact Information
D9212 is domiciled in Nairobi, Kenya. If you have any questions about D9212 Privacy protection policies or practices, please contact us at tech@rotaractdistrict9212.org .

Last modified: 24 June 2021