Privacy Policy - IJM Singapore

Effective date: 11 October 2023

International Justice Mission (“IJM,” “we,” “us,” or “our”) is committed to privacy and data protection. This Privacy Policy applies to your personal data that IJM may collect, disclose and use, through our interactions with you, through www.ijmsg.org that link to this Privacy Policy, and our services, including any personal information collected from our donors (collectively “Services”), as well as how we use and protect your personal data.

We have adopted this Policy to safeguard your Personal Data and to protect your rights and interests and to address your complaints related to Personal Data in accordance with Applicable Laws.

We do not rent or sell your personal information with any person, business or organization, ever. We commit to uphold transparency, accountability, and choice regarding the collection of your personal data. We are committed to using the personal data you provide to only support your relationship with IJM. IJM is also committed to ensuring that your personal data is accurate and complete.

IJM Singapore is related to other IJM entities. In countries in which we do business, the privacy principles set out in this Privacy Policy are supplemented by more detailed privacy policies that reflect the requirement of those countries. We comply with data protection regulations in jurisdictions where we do business.

By interacting with us, submitting information to us, accessing our website or otherwise engaging in any services offered by us, you agree and consent to IJM collecting, using and disclosing your Personal Data and disclosing such Personal Data to IJM’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

Visitors to www.ijmsg.org can browse our website without providing any personal data.

Scope

This Privacy Policy describes the information that we collect, use or disclose (directly or indirectly) and why we collect, use or disclose it, what we do with the information we collect, use or disclose and how you can manage your Personal Data (defined below).

This Privacy Policy does not apply to any website or service that does not display, incorporate by reference, or link to this Privacy Policy. Our Site includes links to other websites whose privacy practices may differ from those of IJM. If you submit personal data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

This Privacy Policy is incorporated into and made a part of IJM’s Terms of Service. If you have not done so already, please also review the Terms of Service.

KEY DEFINITIONS

Applicable Data Protection Guidance means applicable data privacy advisory guidelines and codes of conduct issued by the relevant regulatory authorities that do not fall within the scope of Applicable Laws.
Applicable Law(s) means the PDPA and PDPR.
Data Protection Officer is the person within the organisation who is responsible for ensuring the organisation’s compliance with Applicable Laws and can be contacted at privacy@ijm.org.
Data Subject means an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identify of that natural person.
DNC means Do Not Call Registry.
PDPC means Personal Data Protection Commission.
Personal Data means any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access.
Personal Data Protection Commission means the Personal Data Protection Commission responsible for the administration of the PDPA.
Process means any operation that is carried out in respect of Personal Data, including but not limited to collecting, storing, using, disclosing, transferring or deleting Personal Data and to obtain, record, uses or hold Personal Data and includes organise, adapt or alter, use or consult, disclose by transmission or otherwise make the Personal Data available or destroy the Personal Data within the scope of Applicable Laws and Applicable Data Protection Guidance in respect of data protection.
PDPA means the Personal Data Protection Act 2012
PDPR means the Personal Data Protection Regulations 2021

Personal Data We Collect

We collect and use Personal Data in connection with your donations and any Services provided to you by IJM, including easing your navigation on our websites, communicating with you, and improving your experience using our Services, processing your donation, issuing receipts, and otherwise supporting your relationship with IJM.

The specific information collected will depend upon your interactions with IJM. Examples of the Personal Data we collect from you:

Contact information such as name, e-mail address, mailing address, phone number;
Billing Information such as credit card number and billing address;
Unique identifiers such as user name, account number, password;
Additional information as needed to support your relationship with IJM, such as minimum age or DOB (to ensure age appropriate content) and tax-payer information (to support tax recovery).

If you do not register with us or otherwise provide us with Personal Data, we only Process the information that your browser transmits to our server. This includes:

Your IP address;
Date and time of the request;
Time zone difference to Greenwich Mean Time (GMT);
Content of the request (specific page);
The access status/HTTP status code;
The amount of data transferred in each case;
Website from which the request comes, browser;
Operating system and its surface;
Language and version of the browser software.

This processing is technically necessary for us to display our website to you and to ensure the stability and security of the website.

Surveys or Contests

From time-to-time we may provide you the opportunity to participate in contests or surveys on our website or elsewhere. If you participate, we will request certain Personal Data from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information.

The requested information typically includes:

Contact information (such as name and shipping address);
Demographic information (such as zip code).

Information from Third Parties

Additionally, we may collect the following information from third party sources, including from public sources:

Marketing information such as additional forms of contact, indicators, or flags used for segmentation purposes;
Demographic information, including census data or third party research for segmentation purposes.

How We Use Personal Data

We will only use your Personal Data when the law allows us to. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that in certain circumstances we are obliged to Process Personal Data from you due to a legal obligation, such as anti-corruption stipulations or statutory retention periods.

IJM uses information that we collect from you for the purposes of:

Purpose/Activity	Type of data
Processing donations including: Manage payments, fees and chargesCollect and recover money owed to usTo register a user as a new donor	Contact information such as name, e-mail address, mailing address, phone number;Billing Information such as credit card number and billing address;
Providing constituents with desired information about IJM and its work worldwide	Contact information such as name, e-mail address, mailing address, phone number;
Sharing Personal Data within other IJM entities or with third parties to provide and improve constituent services and provide constituents a service which is suitable to their requirements	Demographic information
Improving and customizing our constituent services and experience, managing our relationship with a user, and using data analytics to improve our website, products/services and donor relationships, which will include: (a) Notification(s) about changes to our terms or privacy policy, (b) Asking a user to leave a review or take a survey	Contact information such as name, e-mail address, mailing address, phone number; Marketing information
Understanding how constituents engage with IJM Global	Demographic information
Communicating with constituents in appropriately customized ways	Demographic information (age, gender, location) and email address; marketing information
Exploring ways to better engage current and future constituents in the mission of IJM Global	Demographic information (age, gender, location) and email address; marketing information
Providing age appropriate content for children	Demographic information (age, gender, location) and email address; marketing information
Supporting tax recovery	Taxpayer and financial information
Maintaining the safety and security of our constituent services, including enhancing protection against spam, harassment, intellectual property infringement, crime, and security risks of all kind; and protecting our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Transaction information, Contact information
Exchanging Personal Data within IJM’s international affiliate offices for the legitimate interests described above, as well as for administrative purposes	Demographic information, Contact information and transaction information
Defending legal claims	Contact information, demographic, financial, transaction and marketing information

The legal basis for processing your Personal Data is made up of one or more of the following reasons: (i) your consent, and/or (ii) providing the services you have requested, and/or (iii) compliance with Applicable Laws, regulations, court orders or other legal process.

We may also collect Personal Data about you from third parties and other sources such as:

your nominated representatives (e.g. spouse or other professional advisors); and
publicly available sources of information.

If you choose not to provide your Personal Data to us for the purposes set out in this Privacy Policy, we may not be able to provide you with the requested information, products or services or to effectively conduct our relationship with you.

Any communication to you can generally only be conducted on an “opt-in” basis by IJM. IJM is not permitted to send “specified messages” (in the form of voice calls, text or fax messages) to Singapore telephone numbers registered with the DNC Registry without the explicit written consent from users who agree to be contacted.

Some exceptions to specified messages include: (1) Informational messages, e.g., to confirm or complete a transaction with an individual; (2) Notification messages e.g. notifications regarding a change of terms of a membership or subscription with an individual; and/or (3) Business to business messages. The Personal Data Protection (Exemption From Section 43) Order 2013 provides an exemption from checking the DNC Registry or obtaining clear and unambiguous consent to send a specified message, under certain conditions.

We may further use information of constituents who attend in person events or trips for our legitimate interest in providing for the safety and security of all event attendees.

Customer Testimonials/Comments/Reviews

We may post customer testimonials/comments/reviews on our website which may contain personal information. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@ijm.org.

How We Use Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes and to distinguish you from other users of our website. We use cookies on this site, for example, to keep track of your preferences and profile information. Cookies are also used to collect general usage and volume statistical information that does not include Personal Data.

Linking third party websites to this website is intended to optimise your user experience and does not indicate any association with or endorsement by IJM. We do not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third party websites. To learn about the Personal Data practices of third parties, please visit their respective privacy notices.

Types of Cookies

We use both session ID cookies and persistent cookies. A session ID cookie is deleted when you close your browser. Although session cookies are established, they are not capturing any behavioral or Personal Data, only information that is helpful to the user experience, such as whether the user’s browser has JavaScript capability. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies are being used to switch one-time messages on and off and to record form completion. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.

If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.

We use cookies for communications purposes and to identify you for subsequent visits if you have an account with us. This way we can improve the use of our website for you. Otherwise, you will have to log-in again for each visit. Our legitimate interest results from the storage of cookies for the technically error-free and optimized provision of our services.

Technologies such as: cookies, beacons, tags and scripts are used by IJM and our partners [e.g. marketing partners], affiliates, or analytics or service providers [e.g. online customer support provider]. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

To make it easier for you to understand why we need them, the Cookies we use on our website can be grouped into the following categories:

Strictly Necessary: These Cookies are necessary for the websites to work properly. They include any essential authentication and authorization cookies for our websites.
Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing our websites, including any preferences you set. They also include sign-in and authentication cookies and IDs that enable you to return without additional sign-in.
Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the websites running on your device. They help us understand which areas you use and what we can do to improve them.
Targeting: These Cookies are used to deliver relevant information related to our websites to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our websites. Some of these types of Cookies on our websites are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our websites.

How to Control and Delete Cookies

Cookies can be deleted, controlled, disabled, blocked or restricted through your web browser settings. Information on how to do this can be found within the “Help” section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments. On the following links, you’ll find information about how to delete or disable cookies from your browser settings:

If you are using a mobile device to access our websites, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device.

Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the websites may not operate properly, and you may not have access to our webpages available through the websites. Except as required by applicable law or this Privacy Policy, IJM shall not be liable for any impossibility to use the websites or degraded functioning thereof, including where such are caused by your settings and choices regarding Cookies.

Social Media Widgets

Facebook Like Button

We use the so-called “two-click solution.” This means that when you visit our site, no Personal Data is initially passed on to the providers of the plug-ins. You can recognize the provider of the plug-in by the marking on the box above its initial letter or the logo. We offer you the possibility to communicate directly with the provider of the plug-in via the button. The plug-in provider receives the information that you have accessed the corresponding website of our online offer only if you click on the marked field and thereby activate it.

Personal information that your browser transmits to our server will also be transmitted. For example, by using the “Facebook Like Button,” the IP address is anonymized immediately after collection, according to the respective website provider. By activating the plug-in, Personal Data is transferred from you to the respective plug-in provider and stored there. Since the plug-in provider collects data mainly via cookies, we recommend that you delete all cookies before clicking on the grayed-out box using your browser’s security settings.

We have no influence on the data collected and data processing processes, nor are we aware of the full extent of data collection, the purposes of processing, the storage periods. We also have no information on the deletion of the data collected by the plug-in provider.

The plug-in provider stores the data collected about you as user profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation takes place in particular (also for not logged in users) for the representation of demand-fair advertisement and in order to inform other users of the social network about your activities on our website. You have a right of objection to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. Through the plug-ins we offer you the possibility to interact with social networks and other users, so that we can improve our offer and make it more interesting for you as a user.

The data is passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected with us will be directly assigned to your existing account with the plug-in provider. If you click the activated button and, for example, link the page, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button, so you can avoid being assigned to your profile with the plug-in provider.

Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the data protection declarations of these providers notified below. They will also provide you with further information about your rights in this regard and setting options to protect your privacy.

How We Share Personal Data

We will not share your Personal Data with third parties without your consent except in accordance with the ways that are described in this Privacy Policy, or for the purposes disclosed on any online form where you provide your Personal Data to us. We do not sell your Personal Data to third parties. In those situations where we use a third party to Process your data, we require that these third parties agree to provide the equivalent level of protection as provided under the applicable data privacy law and this Privacy Policy.

Third parties may be suppliers that Process Personal Data on our behalf, such as:

IT service providers;
Companies that assist with customer service, shipping, or event registration;
Companies that provide other services to support our relationship with you;
Companies that provide demographic and market research assistance.

We may disclose your Personal Data to third parties:

As required by law such as to comply with a subpoena, or similar legal process;
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; or
With your prior consent to do so.

Donations

Specific to donations, IJM uses Plaid Inc. (“Plaid”) to gather End User’s data from financial institutions. By using our service, you grant IJM and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

In addition, any office within the IJM network may share Personal Data you provide it to the IJM Global office in the United States, or another member of the IJM Global team, so that the receiving IJM office may engage with users located in their country and as otherwise necessary to manage the provision of suitable services to constituents as appropriate for their needs.

Handling of Personal Data

Retention of Personal Data

To the extent permissible by Applicable Law, we will only keep your Personal Data for such period as necessary to satisfy or to fulfill the following conditions:

the purposes for which you provided that information,
an identifiable and ongoing business need, including record keeping,
a specific legal or regulatory requirement, and/or
a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.

We will retain your information for as long as your account is active or as needed to provide you Services. If you wish to cancel your account or request that we no longer use your Personal Data to provide you Services, contact us as described in this Policy. We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security of Personal Data

The security of your Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. IJM Global takes the appropriate security measures to keep your Personal Data safe. We implement reasonable administrative, organizational and technical safeguards and security measures to protect all Personal Data within our control from unauthorized access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. While, we cannot guarantee its absolute security, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

If you have any questions about security on our website, you can contact us at privacy@ijm.org. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). The Personal Data collected when you make a contribution or purchase items by credit card is kept for the purposes of tracking your order and to provide a receipt of the transaction. This information is stored on an encrypted, secure server managed by a third-party commercial credit card processing institution.

Transfers of Personal Data

With the global geographical diversity of our operations, it is essential that IJM shares information across multiple jurisdictions. We may therefore transfer your Personal Data across multiple jurisdictions. Accordingly, insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy, we may transfer and store your Personal Data:

in or to the United-States where our head office is located;
in those countries in which we operate, including (but not confined to) Singapore, Australia, South Korea, Hong Kong, Philippines, Thailand, Malaysia, Indonesia, Cambodia, and Myanmar,
in such other countries where our third party service providers, advisors and consultants are located, which changes from time to time.

Such transfers may be to a country which may not provide the same level of privacy protection as that provided by the country in which the information was collected. However, when we use external service providers based outside the European Economic Area to Process your personal information, we do so pursuant to the standard contractual clauses for data processors approved by the European Commission to ensure an appropriate level of data protection. These service providers have been carefully selected by us, commissioned in writing and are bound by our instructions. They are regularly checked by us. The service providers will not pass this data on to third parties, but will delete it after fulfilment of the contract and the conclusion of legal storage periods, unless you have consented to further storage.

When a member of the IJM network located within the EU, or otherwise serving as a controller for Data Subject, transfers personal information to the IJM office or any other office within the IJM network located outside of the EU, we rely on the standard contractual clauses for data controllers approved by the European Commission to ensure an appropriate level of data protection.

Your Rights Regarding Your Personal Data

IJM respects your right to access and control your Personal Data. You have choices about the data we collect. When you are asked to provide Personal Data that is not necessary for the purposes of providing you with our Services, you may decline.

We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us at privacy@ijm.org. We will not discriminate against you for exercising any of your rights to access and control your Personal Data.

Access to personal data: You have the right to request access to a copy of your Personal Data. Subject to any relevant legal requirements and exemptions, including identity verification procedures, we will provide you copies of your Personal Data. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.

Correction and deletion: You have the right to correct or amend your Personal Data if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Data. Please note that such a request could be refused because your Personal Data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.

To review and update or delete your Personal Data, contact us at privacy@ijm.org. We will respond to your request to access within 10 days.

If you are a donor, you may use our donor portal to update your Personal Data.

Consent withdrawal: You have the right to withdraw consent and request us to stop using your Personal Data for any or all of the purposes listed in this Privacy Policy. Under the PDPA, individuals have the right to withdraw their consent for the collection, use or disclosure of their Personal Data, provided that they first give reasonable advance notice of this withdrawal.

Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail, or telephone about IJM products, services and events that may be of interest to you, including our newsletter.

E-mail communications you receive from IJM will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. Please remember that even if you opt-out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.

The right to object to processing: You have the right to object to IJM Global’s processing of your Personal Data, under certain conditions – in particular, where we do not have to Process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing (see below “Choice/Opt-Out”).

The right to data portability – You have the right to request that IJM transfer the data that we have collected to another organization, or directly to you, under certain conditions.

These rights may be limited. For example, if fulfilling your request would reveal Personal Data about another person, would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Our legal rights and remedies in such event are expressly reserved. Relevant exemptions are included in applicable data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

If you wish to exercise any of the rights set out above, please contact IJM at privacy@ijm.org. To protect your Personal Data, we may require that you prove your identity to us at the time your request is made. This may involve providing us with information which we hold on file about you (e.g. a home or business address), or we may require you to produce some form of photo or government issued identification.

Children’s Privacy

Services are not intended for Children.

You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. If we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.

Choice/Opt-Out

Where you have provided your consent, you have the right to withdraw your consent to our processing of your personal information. For example, you may choose to stop receiving all or certain types of communication by following the unsubscribe instructions included in these emails or you can contact us at privacy@ijm.org. You can further choose to withdraw your consent to our processing of your personal information related to an online account (e.g., donor portal) by closing your account through your account settings and then emailing privacy@ijm.org to request that your personal information be deleted, except for information that we are required to retain. This deletion is permanent and your account cannot be reinstated.

We will however keep a record of the fact that you have asked us not to send you direct marketing or to Process your data.

Changes to Our Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by e-mail (sent to the e-mail address specified in your account) or by means of a notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

If you have any questions about this Privacy Policy or would like to access, update, or delete your Personal Data, contact us at:

International Justice Mission
PO Box 2227
Arlington, VA 22202

Phone: 844-422-5878

Email: privacy@ijm.org

We will respond to your request to access within 10 days. If you are a donor, you may use our donor portal to update your personal information.

Amendments

This notice will be subject to change from time to time. The effective date of this current Privacy Policy is set out at the end of this document. Your use of this website constitutes your acceptance of the current terms as set out in this Privacy Policy.

IJM Singapore’sPrivacy Policy