INTRODUCTION 

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy also sets out your rights to control personal information we hold about you. Please read this Privacy Policy carefully in order to understand our practices regarding your personal data and how we will treat it. This Privacy Policy will be updated from time to time. Please come back and check it whenever you wish.

Torchbearers of the Capernwray Missionary Fellowship, with registered office: P.O. Box 3340, Estes Park, CO 80517, registered in the United States of America as a charitable organization with EIN number: 59-1471622 (hereafter referred to as “Torchbearers International”, “TI”, “we“, “us” or “our”) is committed to protecting and respecting your privacy and will only process personal data you provide to us in accordance with applicable privacy laws.

The definition of “personal data” (see under “Definition below) will differ depending on applicable law. In Europe and for European residents, it will include all information that directly or indirectly relates to you and includes “personal data: as defined by the General Data Protection Regulation (“GDPR”). Where GDPR or other EU privacy laws apply to you, this Privacy Policy explains how you can exercise your rights.

For all data matters contact John Poysti, our Data Protection Representative at privacy@torchbearers.org

DEFINITIONS 

“Data controller” – determines the purposes and means of processing personal data and means Torchbearers International in this Privacy Policy;

“Data processor” – is responsible for processing personal data on behalf of a data controller;

“Data subject” – a natural person;

“Personal data” – any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier, for example name, passport number, home address or private email address and online identifiers include IP addresses and cookies;

“Processing” – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Special categories personal data” – as set out in the GDPR, the special categories specifically including genetic data, and biometric data where processed to uniquely identify an individual and other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs;

“Third party” – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

SECTION 1 — IF YOU ARE UNDER 13 

We do not and will not knowingly collect information from any unsupervised minor under the age of 13. If you are under the age of 13, you may not use our website unless you have the consent of, and are supervised by, a parent or guardian.

SECTION 2 — THE PURPOSE OF PROCESSING YOUR PERSONAL DATA 

We use your personal data for the following purposes:

• Communicating with students, guests, alumni, customers, previous donors and current and potential supporters with updates and news;
• Providing benefits and services to students, guests, alumni and supporters;
• Furthering our charitable mission (which includes fundraising and securing the support of volunteers);
• Enabling us to achieve our strategic and operational goals.

SECTION 3 – THE CATEGORIES OF PERSONAL DATA CONCERNED 

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

Personal data including, without limitation:
• your name, sex and date of birth;
• your postal address;
• your phone and email address;
• where relevant, your parent/guardian and their contact details;

In respect of applications to attend one of our Bible schools as a student or to serve as a volunteer at one of our centers, in addition to the above:
• your personal image (photo);
• your education records;
• your career and employment history;
• your marital status and details of any children;
• your nationality, passport and social security number;

Where you are a donor to Torchbearers International:
• your donation and/or pledge details

Financial data including bank account and payment bank details;

Financial transaction data including details about payments and donations from you and details of products and services you have purchased from us and activities you have participated in;

Historical transaction data including communication history, your past donations, purchases, applications and interactions with us;

We process special categories of data including, without limitation:
• your health, including any disability;
• dietary requirements;

In respect of applications to attend one of our Bible schools as a student or to serve as a volunteer at one of our centers, we additionally process the following special categories of data including, without limitation:
• your ethnic origin;
• your race;
• your religion (including place of worship);
• any criminal offences you have committed;
• your physical and mental health history.

The vast majority of the information we hold is obtained directly from our forms that you have filled in (such as contact forms, booking forms, registration forms and events forms).

SECTION 4 – WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA? 

We use your personal data for the following purposes:

a) Personal data
We process your personal data in pursuit of our legitimate interest in fulfilling the purposes set out in Section 2 of this Privacy Policy.
While we rely on legitimate interest as the legal basis for processing, where this is not overridden by the interests and rights or freedoms of the data subjects concerned, we recognize that it is not the only lawful ground for processing data. As such, where appropriate, Torchbearers International will sometimes process your data on an alternative legal basis – for example, because you have given us consent to do so, or to fulfil contractual obligations we may have when you request services from us.
We may also need to disclose your information to a third party if required by law (for example to government bodies and law enforcement agencies), including for the purposes of investigating a complaint, or if we have your permission to do so.

b) Special categories of personal data
To the extent we process your special categories of personal data, in addition to pursuing our legitimate interest in fulfilling the purposes set out in Section 2 of this Privacy Policy, we have obtained your explicit consent, or it may be necessary for reasons of public interest in the area of public health.

SECTION 5 – SHARING YOUR PERSONAL DATA 

Your personal data will be treated as strictly confidential. We will not disclose or share your personal information (including your email address) with anyone outside our organization without your permission.

However, we may need to use or share your information with our partners and agents who provide goods and services to you on our behalf. Your information may be disclosed to:

other parts of our organization (TI);

public or regulatory authorities (if required by law);

third-party service providers, including:

cloud service providers for the hosting of apps and sites;

email marketing service providers (e.g. MailChimp); and

companies that assist us in processing your donations and payments.

We take steps to safeguard your information and we have contractual provisions requiring all third-party service providers to respect the security of your personal data and to treat it in accordance with our data protection policies and all applicable laws. We will not allow third-party service providers to use your personal information for their own purposes and they will only be allowed to process your personal information in accordance with our instructions.

SECTION 6 – HOW LONG DO WE KEEP YOUR DATA? 

We keep your personal data only as long as is necessary for the purpose(s) for which it was collected (unless otherwise advised). Data will be kept securely and destroyed when no longer required. We may also decide to archive some data.

SECTION 7 – PROVIDING US WITH YOUR PERSONAL DATA 

We require you to provide us with your personal data in order for us to fulfil the purposes set out in Section 2 of this Privacy Policy.

SECTION 8 – YOUR RIGHTS AND YOUR PERSONAL DATA 

The following rights under the GDPR are available to you if you are located in the EEA. If you wish to exercise any of these rights, please email privacy@torchbearers.org. We will respond to your request within 30 days of accepting it. Before accepting your request, we may need to ask for some identity proof from you, to make sure we don’t inadvertently provide your personal information to someone else.

If you are not in the EEA, you may still apply for any one of these rights, and we will comply where the request is reasonable as per our discretion.

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing of your special categories of personal data at any time, where consent was the lawful basis for processing such data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics). 

SECTION 9 – INTERNATIONAL TRANSFER OF DATA 

We are an international organization and we might need to transfer your personal information to other countries. If you are in the European Economic Area (EEA), please be aware that we may need to transfer your data to countries outside the EEA to process it. We will only transfer your personal information outside the EEA with adequate safeguards in place and in full compliance with applicable laws. For example, we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection. We have established standard contractual clauses with our service providers to ensure they protect your information and to enforce legal transfers of data internationally.

Please note that personal information submitted to us via the website that we use for Bible school applications is stored by a third-party data processor on a secure server located in Germany. However, your personal information may also be sent to, processed by and stored by other centers that form part of Torchbearers International, in connection with the purposes set out in Section 2 of this Privacy Policy. A list of Torchbearers International centers can be found at: https://torchbearers.org/centres-overview/.

Please also be aware that not all countries offer the same level of data protection as your home country, although our collection, storage and use of your personal data will continue to be governed by this Privacy Policy.

SECTION 10 – LINKS 

Our website contains links to other websites operated by third parties. Please note that this Privacy Policy applies only to the personal information that we collect, and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the Privacy Policy of each website you visit carefully.

SECTION 11 – COOKIES 

Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site by placing small text files on your computer when you visit the website. Please see the table below for an explanation of the cookies we use, and why we use them and for how long the information is saved.

You may change your website browser settings to reject cookies, although please note that if you do this you may not be able to fully experience certain interactive features of our site or access all of the services provide through the site. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.

SECTION 12 – ONLINE APPLICATION FORMS 

Third-party providers: Formstack, CubeMedia, PayPal and MailBigFile (MBF)

We use third-party providers to collect data on our behalf, including if you are attending a Torchbearers International event, applying to a Torchbearers Bible schools, or if you wish to make a donation to us. These third-party providers are data processors for us and only process personal information in accordance with our instructions.

SECTION 13 – ELECTRONIC NEWSLETTER 

We may use a third-party provider to deliver our e-newsletters. In that case, we may also use industry standard technologies to gather statistics around email opening and clicks, to help us monitor and improve our e-newsletter.

SECTION 14 – SOCIAL MEDIA 

Third-party providers, including: Facebook, Instagram, Vimeo and YouTube. If you send us a private or direct message via social media, it will not be shared with any other organizations.

SECTION 15 – EMAILS 

We monitor any emails sent to us for viruses or malicious software, including file attachments. Please be aware that you have a responsibility to ensure that any email you send is within the confines of the law.

SECTION 16 – SECURITY AND PERFORMANCE 

We use a third-party service to assist in maintaining the security and performance of our website, which requires the processing of website users’ IP addresses to do so. While we take appropriate technical and organizational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the internet to us.

SECTION 17 – AUTOMATED DECISION MAKING 

We do not use any form of automated decision making.

SECTION 18 – FURTHER PROCESSING 

If we wish to use your personal data for a new purpose not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

SECTION 19 – CALIFORNIA PRIVACY RIGHTS 

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. Please be aware that not all information sharing is covered by the “Shine the Light” requirements.

SECTION 20 – CHANGES TO OUR PRIVACY POLICY 

Please check back regularly to keep informed of updates to this Privacy Policy as you will be deemed to have accepted any changes if you continue to use our website after an update has been posted.

SECTION 21 – HOW TO MAKE A COMPLAINT 

We endeavor to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously and encourage individuals to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate, and welcome any suggestions for improving our procedures.
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Representative, John Poysti, at privacy@torchbearers.org

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with your local data protection authority.

THIS POLICY WAS LAST UPDATED (SEPTEMBER 2, 2020