This Privacy Policy describes how and when the 22STARS FOUNDATION collects, uses, and shares information when you make a donation, contact us, or otherwise use our services through foundation22stars.org or its related sites and services. This Privacy Policy does not apply to the practices of third parties that we do not own or control. 

You are able to enjoy our blog posts, and visit many areas of our websites without providing us with any personal information. However, we do collect personal information when you sign up to become a long-term sponsor of one of our 22STARS kids, a monthly sponsor of our causes or subscribe to receive email alerts. By making a donation to our cause and/or by using our website, you are agreeing to our Terms and Conditions, which you acknowledge that you have read and understood and that you agree to be bound by these Terms & Conditions. 

1. Personal information 22STARS FOUNDATION collects

Information We Collect


To sponsor a specific child long-term, you must provide us with certain information, such as your name, email address, payment information, and the name of the child that you like to sponsor. This is necessary as we will send you regular updates with regards to the child that you sponsor and or our ongoing project. You may also choose to provide us with additional personal information if you contact us directly. 

We treat your information very confidential. If you like to be an anonymous sponsor of a child, or make an anonymous donation to one of our causes, we will not publish your name related to the cause or specific child anywhere. 

If you like to sponsor a child publicly we will put your name on our website and social media in relation to the specific child you sponsor or cause you made a donation to. We don’t publish any other details of you and don’t give your contact details to anyone outside of our organization, neither the child that you sponsor will receive your contact details.  

To make a general donation, you do not have to provide us with any data and hence can send us money which we treat as an absolute anonymous donation. 

2. The legal bases we rely on to collect, use, and share personal information

Why We Need Your Information and How We Use It

We rely on a number of legal bases to collect, use, and share your information, including:
•	as needed to provide our services, such as when we use your information to send you emails and updates with regard to the child that you sponsor, to settle disputes, or to provide support;
•	when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for my mailing list;
•	if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your donation if required by tax law; and
•	as necessary for the purpose of our legitimate interests, if those legitimate interests are not overridden by your rights or interests, such as providing and improving our services. We use your information to provide the services you requested and in our legitimate interest to improve our services. 
	

3. The third parties with whom we share personal information

Information Sharing and Disclosure

Information about our sponsors is important to our foundation in order to send regularly reports about the sponsored children and in order to send out the new payment for future school terms. We share your personal information for very limited reasons and in limited circumstances, as follows:
•	Service providers. We engage certain trusted third parties to perform functions and provide services to our website. We will share your personal information with these third parties, but only to the extent necessary to perform these services.
•	Foundation transfers. If we stop or merge our foundation, we may disclose your information as part of that transaction, only to the extent permitted by law. 
•	Compliance with laws. We may collect, use, retain, and share your information if we have a good faith belief that it is reasonably necessary to: (a) respond to legal process or to government requests; (b) enforce our agreements, terms and policies; (c) prevent, investigate, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our customers, or others.

4. The length of time we keep personal information

Data Retention

We retain your personal information only for as long as necessary to provide you with our services and as described in our Privacy Policy. However, we may also be required to retain this information to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements. We generally keep your data for the following time period: 4 years. 

5. If we transfer personal information outside of Europe, we will handle the transfer as following

Transfers of Personal Information Outside the EU

We may store and process your information through third-party hosting services in the US and other jurisdictions. As a result, we may transfer your personal information to a jurisdiction with different data protection and government surveillance laws than your jurisdiction. If we are deemed to transfer information about you outside of the EU, we rely on Privacy Shield as the legal basis for the transfer, as Google Cloud is Privacy Shield certified.

6. Our donor’s rights regarding our use of their personal information and our contact details

Your Rights

If you reside in certain territories, including the EU, you have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below:
•	Access. You may have the right to access and receive a copy of the personal information we hold about you by contacting us using the contact information below. 
•	Change, restrict, delete. You may also have rights to change, restrict our use of, or delete your personal information. Absent exceptional circumstances (like where we are required to store data for legal reasons) we will generally delete your personal information upon request. 
•	Object. You can object to (i) our processing of some of your information based on our legitimate interests and (ii) receiving marketing messages from us after providing your express consent to receive them. In such cases, we will delete your personal information unless we have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons. 
•	Complain. If you reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority.

7. Our Sponsor Child Privacy

Respecting the privacy of our sponsor children and their families is a key element of our work. 22STARS Foundation extends the same attitude of respect and confidentiality to our sponsor children as given to their sponsors.


How to Contact Us

For purposes of EU data protection law, I, Stella Airoldi, founder and project manager of 22STARS FOUNDATION, am the data controller of your personal information. If you have any questions or concerns, you may contact me at info@foundation22stars.org. Alternately, you may mail me at:
Stella Airoldi, Kasteelplein 73, 4811 XC, Breda, Netherlands