It is your duty to inform us of changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The Information and Data We Collect
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). It includes information that identifies you personally, such as your name, address, telephone number, technical data, and email address. We collect and store the personal information that you have provided us via one of the email addresses identified on our website or when you otherwise contact us in person, by phone or email, for any reason. We also collect your name, email address and other contact information if you register for an event, as well as collecting your name, email address, mailing address, telephone number, and payment information when you make a contribution, either on our website, at a special event, over the phone or by mailing in a check. The above list provides a sample of personal information that may be collected by CAI. From time to time, we may collect personal information from you in other ways, including from those who subscribe to our newsletter or blog, those who visit our website (see our policy on cookies) and request information about CAI. CAI will NOT sell, rent, or trade this information to a third party for fundraising or marketing purposes, nor will CAI send donor mailings on behalf of other organizations. CAI will only share or sell personal information once the donor has given CAI specific permission to do so.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, and gender.
- Contact Data includes email address, street address, and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, support our programs, or otherwise interact with our delivery of services.
- Marketing and Communications Data includes your preferences in receiving “marketing” (including donation support requests) from us and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used and otherwise protected in accordance with this privacy notice.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Donations made to CAI are safe and secure. CAI uses industry-standard SSL (Secure Sockets Layer) encryption to protect the confidentiality of personal information and the security of all transactions made through the websites.
When making a donation, we use your mailing or email address to communicate directly with you, as well as to send your tax-deductible receipts for all donations, unless other instructions are provided. Donors and supporters may choose to opt out of receiving CAI communications at any time.
If you fail to provide personal data. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or process contributions). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
CAI does not intend – and this website is NOT designed – to collect personal information from children under age 18. Anyone under 18 years of age should not provide personal information or use this site without the supervision or authorization of a parent or legal guardian.
Please note that children under the age of 18 may not make donations on this website without parental consent.
How We Collect Data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or providing other information via our website, in person, by mail, or by email. This includes personal data you provide when you:
- Visit our website;
- make a donation;
- subscribe to our publications;
- request marketing to be sent to you; or
- volunteer or provide us with feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. For further details and information on how to turn off Cookies in your browser, please see our Cookies Policy.
Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:
- Technical Data from the following parties:
- analytics providers [such as Google based outside the EU];
- Our social media pages:
Legal basis for using your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, unless you are a citizen of the European Economic Area (EEA and/or EU) or a citizen of the UK, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us email@example.com.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data.
||Type of data
||Lawful basis for processing including basis of legitimate interest
(d) marketing and communications
|(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how you use our website)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, as well as network security.
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and to you and measure or understand the effectiveness of the information we serve to you
(e) marketing and communications
|Necessary for our legitimate interests (to study how the public supports our mission.
|To use data analytics to improve our website, services, fundraising, marketing, donor relationships and experiences
|Necessary for our legitimate interests (to keep our website updated and relevant.
|To make suggestions and recommendations to you about services that may be of interest to you
|Necessary for our legitimate interests (to develop our fundraising and increase our donations)
Fundraising and Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around fundraising, marketing and advertising.
Donation Requests/Program Marketing
We may use your Identity, Contact, Technical, Usage and Profile Data to solicit monetary or volunteer support, or to form a view on what we think you may want or need, or what may be of interest to you. We call this fundraising or marketing.
You will receive fundraising and marketing communications from us if you have requested information from us or made a donation to CAI, in each case, you have not opted out of receiving that marketing.
We may share information with third-party partners for the purposes of hosting events. Outside of hosting events, we will get your express opt-in consent before we share your personal data with any company.
You can ask us or third parties to stop sending you fundraising or marketing messages at any time by contacting us at firstname.lastname@example.org. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service provided to you.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Definitions (below).
- External Third Parties as set out in the Definitions.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
EEA/EU Citizens and international transfers
If you are a citizen of the EEA, in order to ensure that your personal data is protected when transferred outside the EEA, a data transfer agreement with the entity assisting with the transfer or on the receiving end of the transfer will be put in place incorporating the EU’s standard contractual clauses.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data to external third parties based outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfill 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.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we may anonymize your personal data (so that 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.
Your legal rights including California Consumer rights under the CCPA
In furtherance and in addition to opt-out rights addressed in the “Opt-Out” section of this policy, under certain circumstances, you have rights under data protection laws in relation to your personal data, including rights for California consumers under the California Consumer Privacy Act (CCPA). You have the right to:
Notice – you have the right to be notified which categories of personal information are being collected and the purpose for which the personal information/data is being used. You also have the right to request and obtain from CAI information regarding: (a) the categories of personal information we collect; (b) the sources from which your personal information was collected; (c) the business or commercial purpose for collecting or selling personal information; (d) categories of third parties with whom we share personal information; and (e) the specific pieces of personal information we collect about you.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it and/or disclosing same.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure or deletion of your personal data. This enables you to ask us to delete or remove personal data that has been collected in the past twelve (12) months where there is no lawful reason for us continuing to maintain or process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing or sale of your personal data, including where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing or selling/sharing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Not be discriminated against for exercising your consumer rights.
Exercising your CCPA Data Protection Rights and Other Rights Described herein
If you wish to exercise any of the rights set out above, please contact us at email@example.com. CAI will disclose and deliver the required information, or take the requested action, free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice from CAI.
Do Not Share My Personal Information
If you wish to opt out of the sharing of your personal information by CAI, please turn off cookies in your browser. See our Cookies Policy for additional information or contact us at firstname.lastname@example.org with questions.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Ability to opt out
Individuals may choose to opt out of receiving CAI communications at any time. To unsubscribe from our email, click the link in the bottom of our notifications. You may also unsubscribe or update your preferences for mail or other communications by contacting us by email: email@example.com or phone: 406-585-7841 or by mailing an update or request to: Central Asia Institute, PO Box 7209, Bozeman, MT 59771.
We may occasionally rent or purchase personal information including names, addresses, and email addresses from a third-party organization/company. Central Asia Institute does not store this personal information unless the person makes a donation to or requests newsletter subscriptions from CAI, or otherwise opts-in to our use of such personal information where required by law.
CAI places advertisements with third parties. CAI is able to obtain personally identifiable information from your voluntary registration through advertising links. The voluntary information you provide is transmitted directly to CAI and treated exactly as if it were data collected from our own sites/platforms.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
External third parties means service providers acting as processors based in the UK and US who provide IT and system administration services.
Contact Central Asia Institute
To ask a question or receive more information, please email firstname.lastname@example.org or call 406-585-7841.