Lamp, Lifeboat, Ladder and Reed Smith ("we", "our", or "us") are committed to respecting your privacy.
We set out more details below under How we collect your personal data.
Who is responsible for your personal data?
For the purposes of the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), the data controller for the data you provide or that we collect in connection with our website is Reed Smith LLP of Delaware USA.
Which personal data do we collect?
When you use our website or when we interact with you, the personal data we collect may include:
- Contact information such as personal identifiers that will include your email address and any other information you provide to us via email.
- Communication preferences, such your preferences in receiving fundraising related information or progress updates about our initiatives from us; and
- Inferences drawn from any of the above categories.
- Please note that we do not collect any financial information, which is processed by our chosen third-party provider of payment processing services, CAF America. We also 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 offences.
- If you connect to us from a social network, such as Twitter, YouTube, LinkedIn, Facebook or Instagram, we will collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, and any other information you have agreed it can share or that the social network provides to us.
For more information on how those social networks collect personal information, please visit their individual privacy policies at:
How we collect your personal data
We may collect personal data about you in a number of circumstances and ways, including:
- When you donate to our fundraising initiative.
- When you make an enquiry about Lamp, Lifeboat, Ladder, or otherwise interact on our website.
- When you interact with us by telephone, email and other electronic communication.
- Automatically in the ways we describe below.
Using cookies and other tracking software, we automatically collect personal data about you when you access and use our websites, blogs, mobile sites, applications, sponsored content on social media sites (the "Online Information"), and information about the device you use to access the Online Information.
For example, we may collect:
- Information about how you view the Online Information (such as the pages you view, the links you click).
- Information about the device you use to access the Online Information.
We use this information to provide you with a good experience when using our website, which may include monitoring and making improvements where appropriate.
Use of your personal information
We will use the personal data listed above if and to the extent necessary to achieve the following purposes:
- To provide updates on our fundraising activities to you.
- To analyse and improve our services and promote our fundraising initiative.
- To comply with our legal and regulatory obligations and requests, including reporting to and/or being audited by national regulatory bodies.
- To personalise and foster the quality of our communications and interaction with you.
- For any other purposes related and/or ancillary to any of the above, or any other purposes for which your personal data was provided to us.
Legal justification for our use of your personal data
We may process your personal data in connection with any of the purposes set out above on one or more of the following legal grounds:
- Because it is necessary for us to do so to perform your instructions.
- To comply with our legal obligations, as well as to keep records of our compliance processes or tax records.
- Because our legitimate interests, or those of a third-party recipient of your personal data, make the processing necessary, provided that those interests are not overridden by your interests or fundamental rights and freedoms.
- Because you have expressly given us your consent to process your personal data in that manner.
Sharing and transferring your personal information
We do not sell, rent or otherwise make personal information commercially available to any third party, and do not intend to do so in the future. We will only use your personal data when the law allows us to allow you to navigate our website, to communicate with you, and for you to share our site and information about our charity to others through social media channels if you so desire. We not share your personal information with third parties for marketing or promotional purposes.
When you provide us with your information, you acknowledge that this information will be transmitted to, stored and processed on servers located in the USA but may be also transferred elsewhere within Reed Smith or to a partner organisation strictly for the purpose of the project and where necessary for that purpose.
How long do we keep your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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 unauthorised 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, regulatory, tax, accounting or other requirements.
The GDPR and other applicable data protection laws provide certain rights for data subjects. You may have the following rights:
- To request details of the information we hold about you and how we process it.
- To have the personal data we hold rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation.
- To lodge a complaint in relation to processing of your personal information with a local supervisory authority.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your personal information’) or that you may not be able to make use of the services offered by Living Group. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations. If you have provided your consent and wish to withdraw your consent, please follow the opt-out links on any marketing message sent to you.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
We must ensure that your personal information is accurate and up to date, where relevant. Therefore, please advise us of any changes to your information by contacting us.
Your Nevada privacy rights
Nevada residents have the right to submit a verified request directing us not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send an email to our designated privacy administrator.
California privacy rights
Your rights under the CCPA
For purposes of this section, the term personal information means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including without limitation any information that is subject to applicable data protection laws, as defined under the California Consumer Privacy Act, California Civil Code section 1798.100 et seq., as amended (CCPA).
No sale of personal information: We do not sell Personal Information.
Access to specific information and data portability rights: You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past 12 months. This right of access includes information about:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The categories of personal information that each recipient received.
- The specific pieces of personal information we collected about you.
Deletion request rights: You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your personal information that it has collected from you and retained, subject to certain exceptions.
Exercising access, data portability, and deletion rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us via the information provided below, or calling us toll-free at +1 800 288 7776.
The verifiable consumer request must:
- Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected Personal Information. This may include requesting that you provide us with at least two or more pieces of Personal Information to match against Personal Information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
- Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
Authorized Agent: Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (Authorized Agent) may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.
Non discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.
Your rights under the California “Shine the Light” law
If you are a California resident, California Civil Code section 1798.83 permits you to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personal information for direct marketing purposes. We do not share personal information about you with any third parties for their own marketing purposes. We are only required to respond to such a request once during any calendar year. To make such a request, you should send a letter to the address listed below. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.
How to submit requests or contact us with questions
To make a request regarding your rights under California law, please send an email to our designated privacy administrator or write to us at the following address:
Reed Smith LLP
Three Logan Square
1717 Arch Street, Suite 3100
Philadelphia, PA 19103
Attn: California Privacy Rights
All information you provide to us is stored on our secure servers. Any donation financial transactions carried out by our chosen third-party provider of payment processing services, CAF America, will be encrypted.
All the information we collect is your e-mail address, and any other information you choose to provide to us in your email correspondence. Lamp, Lifeboat, Ladder, and Reed Smith do not see and cannot access any other information about you, such as your financial details provided to our third party vendor for payment. However, for your contact details that you choose to provide, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
If you want to learn more about advertising networks or opt-out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising you can visit the opt-out options of each of those organizations. Here are links to the sites of those organizations:
Network Advertising Initiative: Browser Opt-Out
Digital Advertising Alliance: Browser Opt-Out
Both Network Advertising Initiative and Digital Advertising Alliance: App Opt-Out
Your device may include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt-out of having certain information collected through apps used for interest-based advertising purposes. When you opt out of personalized advertising, you may continue to see online advertising on the website and/or our ads on other websites and online services. Since this opt-out relies on cookies, if you delete your cookies, you will need to opt-out again.
Even when you opt-out of personalized advertising, you may continue to see online advertising on the website and/or our ads on other websites and online services.
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