Privacy Policy

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Overview

Artistic Frames strongly believes that you have the right to control the use of your personal information, and that your privacy must be respected. We strictly limit the collection and processing of your personal data, and to the best of our abilities we will work only with other organisations who do the same. We will not use personal data that you provide to us in a manner inconsistent with the purposes for which you provided it to us, as set out below.

We do not sell, rent or lease personal data.

We will vigorously challenge any attempts by government agencies or private sector organisations to gain access to any information that you give us.

This Privacy Policy (the "Policy") outlines in detail our organisational and website data collection and processing practices in various sections:

• Organisational Privacy Policy
• What Personal Data Do We Collect and Processv
• Why Do We Collect and Process Personal Data?
• How Do We Protect Personal Data?
• Who Do We Share Personal Data With?
• How Long Do We Keep Personal Data?
• Communications
• Supporter and Donor Information
• Website Privacy Policy
• Cookies Policy
• Third party cookies
• Social Media
• Applicants' Information
• Research and Investigations
• Your Data Subject Rights
• How to Contact Us
• Changes to the Policy
• Revisions

Organisational Privacy Policy

What Personal Data Do We Collect and Process?

Artistic Frames collects and processes as little personal data as possible in order to achieve our mission, which is described on our About Us page.

We collect and process various types of personal data depending on your relationship with PI. We may collect and process personal data relating to the following people:

• Employees
• Trustees
• Fellows
• Contractors/ Consultants
• Employees of PI Partners
• Individuals who signed up to our mailing list
• Individuals who take action to support a campaign on our Action Platform
• Website users (see [https://artisticframes.co.za] and [Cookies] Policies)
• Individuals who contact Artistic Frames directly
• Research subjects

The types of personal data we may process, for the purposes described below, include:

• Name
• Email address
• Home address
• Phone number
• Biographical information
• Nationality
• Immigration status
• Employment and employer details
• Communications Preferences (primarily through our Mailing List)
• IP addresses
• Pages accessed on any of Privacy International’s websites
• History of actions taken on our campaigns and fundraising website
• Cookie session data (as described further in our [Cookies Policy])

Generally, we do not collect or keep a record of sensitive personal data and only do so in very limited circumstances, primarily when an individual has chosen to provide us with this data.

We process some sensitive personal data for Human Resource purposes, for example, about PI’s employees as far as necessary to fulfil our duties as an employer. On occasion we may also process sensitive personal data of others engaging with PI, for example where an individual provides us with information relating to accessibility needs for the purpose of arranging a meeting or where an individual contacts PI and their communication includes sensitive personal data. We do not use this data for any other purpose other than that for which it is provided.

We may on occasion process sensitive personal data in relation to our [research and investigations], for example when conducting research into potential or current subjects and participants of our research and investigation projects in the context of Artistic Frames mission. This data may be provided to us by the individuals themselves, from publicly available sources or from third parties.

We also collect and process data in connection with our Action Platform. Privacy is an internationally recognised human right. However, we appreciate that in certain circumstances, the data you submit on this website may reveal data that could be considered sensitive personal data (reflective of your political or philosophical views) e.g. indicating that you are interested in privacy in a specific country, have sent a letter to a specific company to complain about its privacy practices, have signed a petition to support one of our campaigns, or have donated to our appeal to support one of our cases.

When using our websites, you are not required, as a statutory requirement or as a necessity to enter into a contract, to provide us with personal data for processing as described in the Policy. Our Action Platform, however, requires minimal information, such as an email address, for you to take an action. You can create an account on the platform without providing any personal data other than your email address, but you can choose to provide us with additional information. More detail about how your personal data is used for the features on the Action Platform is provided when you are inputting the data.

Why Do We Collect and Process Personal Data?

We collect and process personal data for the following necessary purposes:

• To administer our websites;
• To respond to any communications, queries or requests for information or services from you, howsoever received;
• For recruitment, employee and human resources management purposes;
• For auditing purposes;
• For procurement of services;
• For managing our relationships with Artistic Frames Partners;
• For research, investigations and campaigns in connection with our mission and charitable objectives, which are described on our About Us page.
• To understand our supporters’ engagement with us and our campaigns;
• To comply with our legal or regulatory obligations; and
• To establish, exercise or defend legal claims.

Artistic Frames will only process personal data when we have a legal basis for doing so. The legal basis that we will rely on will depend on the circumstances in which we collect and use your personal data. In almost all cases, the relevant legal basis to process personal data is that the processing will be one of the following:

Based on your consent to use your data in a certain way (for example, to communicate with you through our mailing list). Your consent may subsequently be withdrawn at any time by editing your preferences or contacting us as specified in the [How to Contact Us] section of this Policy without affecting the lawfulness of processing based on consent before its withdrawal. Necessary in order to take steps prior to entering into a contract or for the performance of a contract.

Necessary to comply with legal requirements (for example, to comply with applicable regulatory obligations and employment law); and Necessary for our legitimate interests (for example, to administer our websites, to carry out research and investigations consistent with our mission. We will only rely on this legal basis where we’ve identified the purpose (the legitimate interest), assessed that the processing is necessary for that purpose and conducted a balancing test to ensure that this interest is not overridden by the interests, rights and freedoms of the individual.

How Do We Protect Personal Data?

Personal data shall be subject to additional safeguards to ensure this data is processed securely. For example, we work hard to ensure data is encrypted when in transit and storage, and access to this data will be strictly limited to a minimum number of individuals and subject to confidentiality commitments.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to any of our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. When possible, encryption is used, both in transit and storage. Access controls within the organisation limit who may access information.

We never transfer your data outside South Africa (zar) unless we have your explicit consent for it, or on the basis of specific safeguards in individual circumstances of which we’ll let you know if they apply to your data.

Who Do We Share Personal Data With?

At Artistic Frames we administer, run, and use a series of services and infrastructure that may process your personal data.

We maintain direct control over as many processes as we can. As necessary in connection with the above purposes, your personal data may be transferred to the Board of Trustees or our authorised third-party service providers and partners. We conscientiously select and review authorised third parties when possible and review their privacy and security policies. These authorised third parties may be engaged in, among other things, the processing of donations, technology support, outreach campaigns, or research projects carried out in connection with our mission. Limited members of Privacy International staff or the staff working for these third parties may also access and otherwise process your personal data in connection with their job responsibilities or contractual obligations.

Some of these personnel and authorised third parties (for example payment processors) may transfer data outside the South Africa. We take appropriate steps to ensure that data remains within jurisdictions with adequate protections for personal data and ensure that recipients of personal data from us are bound to duties of confidentiality, where relevant or appropriate. Where this is not possible, we rely on data minimisation, and as much as possible, the selection of trusted companies with privacy policies and auditable processes which we have reviewed, and seek to ensure that there are adequate safeguards in place for protecting transferred data, for example Standard Contractual Clauses. For more information on the safeguards for transfer in a particular operation please contact us. We may also be required to disclose or otherwise process your personal data in the context of a regulatory audit to which we may be subject from time to time.

These services may include:

Internet resources we administer and control but are hosted by third parties, e.g. our website (https://artisticframes.co.za/ and our onion service) and our media server, services we use to work with our board and partners, a URL shortener, our analytics service, our external cloud, and our search server. These are hosted by providers who will have log data and with whom we have data processing agreements under which they act as processors for us. Servers are currently hosted by Host4Africa. Internet resources for which we are administrative users but that are operated by third parties with whom we have data processing agreements under which they act as processors for us, e.g. our Action Platform.

Internet resources we do not control where we have accounts operated by third parties, e.g. SIP phone, email, social media, third party content providers (search engines, podcasts, video), surveys, payment processors, calendaring, conferencing services. These third parties have privacy policies in place that govern how users' data are used: phone, email, survey, calendaring, conferencing services.

Infrastructure providers we use where data may be processed, e.g. cloud backup services (though data is encrypted at rest), DNS and CDN, certificate authorities, and service uptime monitors. These providers have privacy policies in place that govern how data are used: backup (Microsoft), DNS and CDN (Cloudflare).

Services where our staff, partners, and trustees’ data may be processed, including our internal services that we host; our external services that we administer and control with a third party host; services we administer but are hosted in the cloud; services where we are administrative users but do not control (e.g. email, calendaring), and services where we are users (e.g. email). These are governed as described above based on agreements and/or policies. Our servers are currently hosted by Host4africa.

How Long Do We Keep Personal Data?

We ensure that personal data is retained only for as long as necessary in accordance with the above purposes and applicable laws. We retain personal data for the following indicative periods:

Communications from the public via our website’s ‘contact us’ form are received by email and are reviewed by Artistic Frames staff, sent onwards when necessary to other staff members, and deleted as quickly as possible. Communications from media and journalists via our website or by direct email to info@artisticframes.co.za are all received by email and are reviewed by a staff member and then sometimes shared with other staff members. Communications from the public with regards to our public accountability are received by email and are exclusively reviewed by Artistic Frames Executive Director.

Emails received from our supporters are reviewed by Artistic Frames staff, sent onwards when necessary to other staff members, and deleted as quickly as possible.

Communications with our stakeholders and adversaries, through our staff email addresses or our public facing email addresses, are treated confidentially. We may publish these communications if we consider it to be in the public interest and in line with data protection law, removing personal information when irrelevant to the purpose of publishing. We do not disclose the names of senders or contents of their communications to others outside of Privacy International, i.e. third parties, without your permission or unless strictly necessary.

We administer a mailing service, on our Action Platform, for notifications by email based on interest in topics that you have explicitly indicated to us. Outgoing messages are processed by our mail service and internet providers.

Information we receive by post is collected and reviewed by PI staff member and sent onwards when necessary to other staff members. These items are retained or destroyed according to our retention policy. We use our best efforts to prevent disclosure of the names of senders to third parties, consistent with our legal obligations and we endeavour to keep files secure. If the content of messages is shared with third parties, we de-identify the messages as much as possible.

Telephone calls received on our number are serviced by our phone and internet provider. The traffic data for these calls may be retained in accordance with various laws on the retention of communications data.

Our contact information

Contact: +27 11 888 3776

Email: info@artisticframes.co.za.co.za

Additional information

Adress: Foto First , Shop 2, Victory Park Shopping Center, Cnr Rustenburg Rd &, 2nd Ave, Randburg, 2195, South Africa.