Effective Date: July 19, 2019
If you are in Europe, “personal information” covers all personal data processed by us, which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly. “Europe” covers the European Economic Area and Switzerland.
2. What Information do We Collect about You?
We collect your personal information when you provide it to us. We may also collect other information that you voluntarily provide to us, such as when you communicate with us via email, post, telephone or other channels; and when you respond to our communications or requests for information. The types of information that may be collected may include, but are not limited to: name, postal address, telephone numbers, email address, debit and credit card details, user name, your interests and activities, and opinions on our Site(s), products and services. We may also collect information about other people that you provide to us, for example when you submit another person’s name and address when you purchase a gift subscription.
Website usage information is collected using web logs and cookies. When you enter the Site(s), we collect your browser and device information, such as IP address. This information is gathered for all Site(s) visitors and users.
We may receive information about you from other sources, such as third parties, and publically available information that help us: update, expand and analyze our records; identify new customers; or prevent or detect fraud. We may also receive information about you from social media platforms, such as when you interact with us on those platforms or access our social media content. Please note that the information we may receive from those third party sites (such as Facebook, Instagram, Twitter, Spotify and Youtube) is governed by the privacy settings, policies and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information to them.
You can choose not to disclose certain information, but then you might be limited in the services you can take advantage of on the Site(s).
Any other information transferred by you in connection with your visit to the Site(s) (that is, information that cannot be used to identify you) may be included in databases owned and maintained by PAO or its agents. PAO retains all rights to these databases and the information contained in them.
We may also enhance or merge your information with data obtained about your online activities over time and across third party websites or other online services for the same purposes.
You also may provide your information to be published or displayed on public areas of the Site(s), or transmitted to other users of the Site(s) or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Any information you post publicly on the Site(s) is available to the public without any expectation of privacy or confidentiality. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site(s) with whom you may choose to share your User Contributions. Therefore, PAO cannot and does not guarantee that your User Contributions will not be viewed by unauthorized persons.
We ask that you do not send us or disclose any sensitive information on or through the Site(s) or otherwise, being personal information relating to: racial or ethnic origins; political opinions; religion or other beliefs; health or medical conditions; trade union membership; sexual orientation; or criminal background. If any sensitive information is freely available or accessible in the public domain, we will not have any obligations to you regarding that information.
However, due to the religious nature of our activities, should we collect personal information that constitutes sensitive information regarding religion or other belief, we will only process such data:
- with your explicit consent;
- if the processing relates to personal information which is manifestly made public by you;
- if the processing is necessary for the establishment, exercise or defense of legal claims;
- if the processing is necessary for reasons of substantial public interest; or
- being a not for profit organization with a religious aim, if the processing is carried out in the course of our legitimate activities with appropriate safeguards and the processing relates solely to subscribers (or former subscribers) or others with whom we are in regular contact in connection with our charitable purposes and such data is not disclosed outside of our organization.
You agree not to post any abusive, obscene, vulgar, slanderous, hateful, threatening, sexually-orientated or any other material that may violate any laws, be it of your country, the country where the message board or community is hosted or internationally. Doing so may lead to you being immediately and permanently banned from some or all of the Site(s), with notification to your Internet Service Provider if we deem it necessary or expedient. The IP addresses of all posts are recorded to aid in enforcing these conditions. You agree that we have the right to remove, edit, move or close any topic at any time should we see fit. As a user you agree to any information you have entered being stored in a database. Any information revealed in a posting to a message board or community becomes public information. Please exercise discretion and caution while using the message board or community. We are not responsible for any third party use of any information you disclose through your use of the message board or community.
We comply with the Digital Millennium Copyright Act. The Digital Millennium Copyright Act lays out a system of legal requirements for dealing with allegations of copyright infringement. DMCA compliance can be viewed here.
3. Users in Europe - What are Our Responsibilities to You?
If you are in Europe, for the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”) and the equivalent Swiss arrangements, we will collect personal information about you and will be the data controller for that personal information. We can be contacted as noted below:
Data Protection Leader
PAO mail address: 640 Plaza Drive, Suite 110, Highlands Ranch, CO 80129, United States
4. How We May Use and Share the Information We Collect
We may use the information we collect:
- to respond to your enquiries;
- to further our charitable aim, which is the advancement of religion;
- to provide you with goods and services that you request, process donations that you make, process returns and refunds, and enable you to participate in events, competitions, sweepstakes and message boards or online communities;
- to present our Site(s) to you and send you marketing communications and other information or materials that may be of interest to you or which you have expressed an interest in receiving, such as email newsletters and print magazines for which you have subscribed;
- to maintain our list of contacts;
- for PAO’s business or charitable purposes, such as: improving the provision of our Site(s), products and services; data analysis; submitting invoices and debt collection; detecting, preventing and responding to actual or potential fraud, illegal activities or intellectual property infringement;
- to better understand your needs and assess the effectiveness of our events, promotional campaigns and publications; and
- as we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protect your, our or others’ rights, such as exchanging information with other companies and organizations for fraud protection and credit risk reduction.
We may share the information we collect:
- with third party service providers engaged by us to perform services on our behalf, such as web-hosting companies, information technology providers, web-development consultants, analytics providers, delivery of goods and services, processing of credit card payments, billing and debt collection, customer services, marketing and communications services and event hosting services;
- with PAO's ministry organization partners (“Partners”) in connection with services that these entities perform with PAO for the collaboration in which they and PAO are engaged: such as providing you with goods and services that you request; providing customer services; and enabling you to participate in events, competitions, sweepstakes, message boards or online communities and surveys;
- with third parties who sponsor or co-sponsor or promote or co-promote an event or a competition, sweepstake, promotion or other activity or offering in which you participate;
- with law enforcement, courts or tribunals, other government authorities, or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided for under contract; or as we deem reasonably necessary to provide our services. In these circumstances, we take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organization, unless giving prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances;
- to protect the rights, property, or safety of PAO or others, such as exchanging information with other companies and organizations for fraud protection and credit risk reduction; and
- with service providers, advisors, potential transactional partners or other third parties in connection with the consideration, negotiation or completion of a transaction in which we are acquired by or merged or amalgamated with another company or we sell, liquidate or transfer all or a portion of our assets.
Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.
If you do not want us to use your personal information in these ways, please choose the relevant response on the form on which we collect your information, adjust your user preferences in your account profile, or contact us as advised in Section 17 below.
5. Legal Grounds for Using Personal Information
We rely on the following legal grounds to process personal information, namely:
Performance of a contract: we may need to collect and use personal information to enter into a contract with you or to perform a contract that you have entered into with us.
Legal obligation: we may need to collect and use personal information to comply with legal obligations to which PAO is subject.
6. Users in California - California Civil Code Compliance
If you are a resident in California in the United States, PAO seeks to comply with the California Civil Code Section 1798.80-1798.84. That law permits you to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. You may only make such a request one time each year.
To make such a request, please contact us as advised in Section 17 below with any questions regarding such use of personal information.
The entire California Civil Code Section 1798.80-1798.84 documentation can be viewed here.
7. The Measures We Have in Place to Protect and Safely Store the Information We Collect
The security of your personal information is important to us. When you enter personal information on the Site(s), we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us from unauthorized access or disclosure, both during transmission and once we receive it. However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. We are not responsible for the security of information you transmit to us over networks that we do not control, such as the Internet and wireless networks.
We use a number of suppliers and service providers in connection with the operation of our business and they may have access to the personal information we process. For example, an IT service provider may see your personal information when providing software support, or a company which we use for processing of credit card payments or a marketing campaign may process your personal information for us. When contracting with suppliers and/or service providers, PAO takes appropriate steps to ensure that there is adequate protection in place and that data protection principles are adhered to.
8. Retention of the Information We Collect
We retain the information we collect for no longer than is reasonably necessary to fulfill the purposes for which we collect the information and to comply with our legal obligations.
Following completion of the services provided by us, we will either retain the related papers or store these records digitally.
Where personal information is retained for the purposes of sharing promotional material, and you no longer want to be contacted by us, please contact us as advised in Section 17 below. Please include your name and mailing address (as well as your e-mail address) if you also prefer not to receive direct mail. Note that you may still receive service related communications from us.
9. Web Log Information
Web log information is gathered when you visit one of our Site(s) by the computer that hosts our Site(s) (called a “server”). The server automatically recognizes some information, such as the date and time you visited our Site(s), the pages you visited, the website you came from, the type of browser you are using (e.g. Internet Explorer), the type of operating system you are using, and location data. It helps us improve our Site(s) and to deliver a better and more personalized service, such as by enabling us to: (a) estimate our audience size and usage patterns; (b) store information about your preferences, allowing us to customize our Site(s) according to your individual interests; (c) speed up your searches; and (d) recognize you when you return to our Site(s).
11. IP Addresses
The Site(s) uses Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet Service Provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a dynamic address). Note, however, that if you have a broadband connection, depending on your individual circumstance, it is possible that your IP address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP address doesn't change (it is static) and could be associated with your personal computer. We use your IP address to report aggregate information on use and to help improve the Site(s).
- How We Respond to Do Not Track Signals and Apply Local Shared Objects, Pixel Tags, Web Beacons, Analytics, Tailored Advertising and Location Information
Do Not Track is a privacy preference that users can set in their browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. For information about Do Not Track, visit www.allaboutdnt.org. At this time, the Site(s) does not respond to Do Not Track browser settings or signals.
In addition, the Site(s) may use other technology that is standard to the Internet, such as local shared objects, pixel tags, web beacons and other similar technologies, to track visitors to or users of the Site(s). Those tools may be used by us, Partners and third parties to collect information about you and your Internet activity, even if you have turned on the Do Not Track signal.
We and a Partner (or third parties on behalf of such Partner) may use third party web analytics services, such as those of Google Analytics. You can also opt out of being tracked by Google Analytics across all websites by installing Google’s opt-out browser add-on.
When you use a smart phone, mobile device or computer to access the Site(s), we may collect information about your physical location. We may combine this information with other location-based information (e.g. your IP address and billing/postal address), to provide you with other services on your device. We share your location information only with third parties that help us provide you with services. You can opt-out of sharing this information by changing the permissions in your device.
The Site(s) is not intended for, or designed to attract, individuals under the age of 13 (or 16 in Europe). We do not knowingly collect or solicit personal information from any person under the age of 13 (or 16 in Europe). No person under the age of 13 (or 16 in Europe) may provide any personal information to or on the Site(s). If you are under the age of 13 (or 16 in Europe), please do not use or provide any information to or on the Site(s) or on or through any of its features, or use any of the interactive or public comment features of the Site(s), or provide any personal information about yourself to PAO, such as your name, address, telephone number, e-mail address or any screen name or user name you may use. If PAO learns that it has collected or received personal information from a person under the age of 13 (or 16 in Europe) without verification of parental consent, PAO will delete that information as quickly as possible. If you believe that PAO might have any personal information from or about a person under the age of 13 (or 16 in Europe), please contact us as advised in Section 17 below. We encourage parents to monitor their children’s Internet usage and/or to use web filtering technology to supervise their children’s access to the Internet.
PAO seeks to comply with the Children's Online Privacy Protection Act instituted in April 21, 2000. The entire COPPA documentation can be viewed here.
14. Updating Your Information, Opt Out Option and Choices about How We Use and Disclose Your Information – Other than if you are in Europe
You may correct, update or remove personal information previously provided to us by contacting us as advised in Section 17 below, as applicable.
15. Users in Europe - Choices and Rights in Respect of the Information We Hold
If you are in Europe, personal information must be processed in line with individuals' rights, including the right to:
- request a copy of their personal information;
- request that their inaccurate or incomplete personal information is corrected;
- request that their personal information is deleted and destroyed in certain circumstances;
- object to processing or request that the processing of their personal information is restricted in certain circumstances or withdraw consent, including to opt out of receiving communications (including electronic) from PAO;
- not be subject to automated decision making; and
- request the transfer of their personal information in certain circumstances.
If you wish to exercise any of these rights, please contact us as advised in Section 17 below.
However, please note that for practical and/or technical reasons it may not be possible to remove certain information contained in User Contributions.
16. Links to other Websites
17. How to Contact Us
If you have any queries concerning your personal information or any questions on our use of that information, please contact us as noted below:
Data Protection Leader
PAO mail address: 640 Plaza Drive, Suite 110, Highlands Ranch, CO 80129, United States
18. Supplemental Privacy Notices