Thank you for your interest in the Atlantic Council Romania. Your privacy is important to us, and we strive to be transparent in our collection and utilization of your information. When we use “Atlantic Council Romania,” “we,” “us,” or “our,” this means the Atlantic Council Romania of the United States. This Privacy Policy (“Policy”) explains what information we collect from or about Donors (as defined below) and visitors and users (collectively referred to as “you,” “your,” “User,” or “Users”) of our websites, including but not limited to www.atlanticcouncil.org and all other Atlantic Council Romania-owned or Atlantic Council Romania-managed web domains that link to this Policy; our online video services; our social media platforms; text messaging services used for communicating with us; and our online and offline Donor platforms (collectively, the “Atlantic Council Romania Services”). The Policy also explains how we collect information, use it, disclose it to third parties, and protect it, as well as how you can opt out of various communication channels relating to your information. For purposes of relevant privacy laws, Atlantic Council Romania is the data controller of your information. Please read this Policy carefully. By being a User and using the Atlantic Council Romania Services, you agree to our collection, use, disclosure, and transfer of your information as described in this Policy and to the terms herein. If you do not agree to this Policy, please do not use Atlantic Council Romania Services. “Donors” means supporters who make donations by any means, including online (such as through online fundraising platforms or our websites) and offline (such as at events or by submitting paper form pledges). This Policy contains the following sections: What information does Atlantic Council Romania collect? How does Atlantic Council Romania use my information? How does Atlantic Council Romania disclose my information? Your rights and choices How is my information protected? How is my information retained? California Privacy Notice Children’s privacy Information for Users outside the United States Links to other sites Changes to this Policy Contacting us What information does Atlantic Council Romania collect? The information we collect about you depends on the Atlantic Council Romania Services you use, how you use them, and the information you provide to us. We collect information in three main ways: (1) information you provide directly to us; (2) information we collect automatically through technology when you use Atlantic Council Romania Services; and (3) information we collect from other sources. Information you provide directly to us When you use Atlantic Council Romania Services, you may provide certain information directly to us. For example, you provide information when you subscribe to our emails, submit any of our online forms, make a donation, or sign up for SMS/text messages. The information we collect directly from you includes: Contact and account information, such as name, mailing address, email address, telephone number, mobile phone number, and username and password if you create an account. Financial and transaction information, such as billing address and payment card or bank account information, if you make a donation or a purchase via the Atlantic Council Romania Services. Please note that this information is collected and stored by our trusted third-party payment processors and not by us. Such third parties’ privacy policies and terms will therefore apply to how they collect and process your payment information. Other information that you provide to us, such as the content of your communications with us and contacts through social media channels. Information we collect automatically When you use Atlantic Council Romania Services that are online (such as our websites), we and our vendors may collect certain information about you automatically using cookies and similar technologies. Cookies are small text files placed on your device that perform a variety of functions, including recognizing your device, remembering your preferences, enabling the Atlantic Council Romania Services to function, assisting with security, and improving our advertising and analytics. Cookies and similar technologies may collect the following information about you: Technical information about your device and your use of Atlantic Council Romania Services, such as your IP address, device identifiers, and information about your web browser (such as language and preferences), operating system, device (such as model and manufacturer), mobile carrier, system configuration data, and activity on our online services (such as pages you visit, links you click, and the webpages you visit before and after visiting the Atlantic Council Romania Services). Location information, such as the location of the device you are using to access our websites (which may be derived from IP-based geolocation). Information we collect from other sources We may collect information about you from other sources, such as social media networks (for example, when you interact with us by liking us on Facebook or Instagram or following us on Twitter), other publicly available sources and databases, data aggregators, marketing companies, and other parties to help us supplement our records. How does Atlantic Council Romania use my information? We may use your information in various ways, depending on the information, including for the following purposes: To provide and maintain the Atlantic Council Romania Services and our operations, including to run our programs and maintain the functioning and security of the Atlantic Council Romania Services. To provide you with goods, services, or interactions you request, such as to facilitate donations through the Atlantic Council Romania Services and enable you to participate in our work as a volunteer, Donor, or otherwise. To communicate with you via email, text, or mail, subject to applicable law and any preferences you have communicated to us, including to send information about events, activities, publications, and donation and volunteer opportunities, contact you about transactions conducted through an Atlantic Council Romania Services, or update you about changes to our terms and policies. To analyze and improve the Atlantic Council Romania Services and our programs, including to improve the Atlantic Council Romania Services’ content and functionality, enhance Atlantic Council Romania Service features that require User input, understand Users’ use of the Atlantic Council Romania Services, and measure interest in our various campaigns and programs. For legal and compliance purposes, including to enforce our terms and policies and protect our legal rights. For any other lawful purpose with your consent. De-identified information: We may de-identify your information or aggregate your information with that of other Users so that it cannot reasonably identify you. We may use and disclose this de-identified or aggregated information to any party for any lawful purpose. Data combination: For the purposes above, we may also combine the information that we collect through the Atlantic Council Romania Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy. Legal bases for processing: The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Policy are as follows: Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the services you’ve requested from us, or to comply with our legal terms and policies. Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to operate and provide security for the Atlantic Council Romania Services, facilitate our programs, receive payments for your purchases, defend our legal rights, and prevent fraud. Where we use your information to comply with applicable legal obligations. For example, keeping track of your donations for tax and auditing purposes. Where you have consented to our processing of your information for a particular purpose. How does Atlantic Council Romania disclose my information? We may disclose your information in the following ways: To affiliated entities. We may disclose your information to affiliates under common ownership and control. To our service providers. We may disclose your information to vendors that provide us with services that help us run our organization and the Atlantic Council Romania Services, including data hosting and storage, help desk software and email service providers, security, research and analytics, donation processing, and legal services. For example, we use Vimeo OTT to power the certain video services we may make available to you and provide you with customer support. You can read more about how Vimeo uses your information here: vimeo.com/privacy. Advertising Partners. Except as provided herein, we may disclose your information to third parties that assist in tailoring and serving advertisements that are relevant to you. We may also allow third-party advertising technologies (e.g., ad networks and ad servers) to use cookies and similar technologies on the Services to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use, as explained further in the “Cookies,” “Online Analytics,” and “Online Advertising” sections below. For legal purposes. We may disclose information if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order); (b) enforce our legal terms, including this Policy, or other contracts with you; (c) respond to legal claims involving us; or (d) protect the rights, property, or personal safety of Atlantic Council Romania, our volunteers, or others. Organizational transfers. If we participate in a merger, acquisition, bankruptcy proceedings, or other transfer or reorganization of assets, including in contemplation thereof, your information may be among the transferred assets. If a portion or all of our assets are transferred to a third party in these circumstances, we may disclose your information as part of the transfer. For other purposes with consent. We may use your information for any other lawful purpose that we disclose to you and to which you consent. Your rights and choices We value your choices and control over your information. Your legal rights to exercise such controls and choices vary based on the laws of your jurisdiction, and may include the following: Access to, or a copy of, your information Confirmation that we are processing your information Correction or amendment of your information Deletion of your information Transfer of your information to a third party Restriction or objection to certain uses of your information If you have provided consent for us to use your information for a specific purpose, you may also request to withdraw that consent. You can exercise the rights listed above at any time by emailing us at info@atlanticcouncil.org. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests (e.g., where we are required to keep information for legal purposes, or where deletion of information would interfere with freedom of expression). Depending on your jurisdiction of residence, if we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process. Marketing communications You may opt out of email communications from us by clicking the “unsubscribe” link at the bottom of the emails. If you are currently receiving SMS/text messages from us and wish to opt out of receiving such messages, you may do so by replying “STOP.” You may also opt out of both email communications and text messages by emailing us at info@atlanticcouncil.org. Please note that if you opt out of marketing communications, we may still send you service-related communications such as an email informing you about a volunteer opportunity that you signed up for, a transaction you completed through the Atlantic Council Romania Services, or a notice of changes to our legal terms, including this Policy. Notice of Right to Opt Out As explained in the “Cookies,” “Online Analytics,” and “Online Advertising” sections below, we provide certain information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, or use related advertising analytics services. The disclosure of your information to these third parties to assist us in providing these services may be considered a “sale” of personal information under applicable law, or, the processing/sharing of personal information for targeted advertising purposes. To opt out of these practices, please use the mechanisms described below. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization. Cookies As mentioned above, we and our vendors use cookies and similar technologies to collect certain information about you. You may be able to set your internet browser or device to stop accepting new cookies, notify you when you receive a new cookie, or disable existing cookies. Please consult the “Help” section of your browser for more information. The setting will apply only to the browser or device you are using, so you will need to make your choices on each browser or device. If you disable some or all cookies, the Atlantic Council Romania Services may not function as intended and some features may be unavailable. For detailed information about the use of cookies in the Atlantic Council Romania Services, please read and review our Cookie Policy. Online analytics We and our vendors may use third-party analytics services on Atlantic Council Romania Services to help us understand how users engage with Atlantic Council Romania Services, including Google Analytics. These parties may use cookies and other technologies to help collect, analyze, and provide us with reports and/or data. For more information about Google Analytics and how it collects and processes data, please visit: https://policies.google.com/technologies/partner-sites. To opt out of Google Analytics using your information for analytics purposes, see: https://tools.google.com/dlpage/gaoptout. Online advertising We may allow third-party advertising technologies (e.g., ad networks and ad servers, or other advertising partners) to place cookies or other tracking technologies on your browser or device to collect information about you to assist in the delivery of relevant advertising on other websites you visit and other online services you use. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. For example, if you visit an Atlantic Council Romania website, you may see ads for Atlantic Council Romania on other websites you visit. We neither have access to, nor does this Policy govern, the cookies or other tracking technologies that may be placed on the device you use to access the Atlantic Council Romania Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt out of receiving tailored advertising from companies that participate in those programs. You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings. How is my information protected? Atlantic Council Romania maintains data security measures in line with current industry standards for the Atlantic Council Romania Services to protect the information under its control against unauthorized access and disclosure. These measures include the implementation of a variety of technical, physical, and administrative data-security safeguards. Please keep in mind, however, that no data transmitted over the internet is 100 percent secure, and any information disclosed online can potentially be collected and used by parties other than the intended recipient. How is my information retained? We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information. Children’s privacy Atlantic Council Romania does not knowingly solicit or collect personal information (as defined in applicable law) from children under the age permitted by applicable law without parental consent. If you are a parent or guardian age and believe that your child disclosed information to us in a way that is prohibited by applicable children’s privacy laws, please contact us at info@atlanticcouncil.org. Information for Users outside the United States Atlantic Council Romania is based in the United States. If you are located outside of the United States, please be aware that we may store and process your information in the United States or any other country in which Atlantic Council Romania or its affiliates or vendors maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer your information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. By using the Atlantic Council Romania Services, you consent to the transfer of your information to such jurisdictions. If you do not want your information to be transferred in this way, do not use the Atlantic Council Romania Services. Links to other sites The Atlantic Council Romania Services may contain links to other sites, products, and services that are external and not owned or controlled by us. We are not responsible for the privacy practices employed by, or content provided by, such other sites, products, and services. We encourage you to be aware when you leave Atlantic Council Romania Services and to review the privacy policies of any third-party websites or services, as you will be subject to their policies, rules, and terms. Changes to this Policy We may change this Policy at any time. Changes will be effective immediately upon posting. Please check this Policy regularly to ensure that you are aware of any changes. Your visit to or use of any Atlantic Council Romania Services after changes to this Policy have been made means you have accepted the changes. We may also provide you with additional notice or options regarding updates to the Policy in accordance with applicable law. If you do not agree with the changes, immediately stop visiting or using Atlantic Council Romania Services. Contacting us If you have any questions about our Policy, please contact us as provided below: For questions about this Privacy Policy, email info@atlanticcouncil.org. You may also write to us at: Atlantic Council Romania 1030 15th Street, NW, 12th Floor Washington, DC 20005 Last updated on March 30, 2023.