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Privacy Policy

Privacy Policy of The Million Project

1. Introduction

1.1. This Privacy Policy applies to The Million Project, a global non-profit organization dedicated to driving positive change for people, animals, and the environment through innovative and impactful initiatives.

1.2. The Million Project is the data controller and is responsible for the collection, processing, and use of personal information in accordance with this Privacy Policy.

2. Information We Collect

2.1. The Million Project may collect personal information from you in the following circumstances:

a. When you provide it directly, such as when making a donation, registering for events/membership, participating in campaigns, volunteering, purchasing products, or communicating through various channels.

b. When you provide it indirectly through third-party platforms, partner organizations, fundraising sites, event registrations, or joint campaigns, where you have consented or it is necessary for a contract.

c. Through your interactions with our website, social media, or online channels, including device information, browsing activities, and preferences via cookies and similar technologies.

d. From publicly available sources, such as media coverage, social media posts, or company records, particularly when researching potential major donors or individuals relevant to our campaigns and advocacy efforts.

2.2. The types of personal information we may collect include:

a. Contact information (name, address, email, phone number)

b. Payment information (bank account details, credit/debit card information)

c. Donation and transaction history

d. Communication preferences

e. Event and membership participation details

f. Volunteer information

g. Demographic information (age, gender, interests)

h. Online browsing and usage data

i. Publicly available information (media coverage, social media posts)

2.3. In certain circumstances, with clear notices and explicit consent, we may collect sensitive personal information such as health status, political or religious views, or criminal records for specific purposes like event accommodations, role suitability assessments, or tailoring communications.

3. How We Use Your Personal Information

3.1. The Million Project may use your personal information for the following purposes:

a. Processing donations, transactions, and related communications

b. Providing updates, marketing materials, project/campaign information

c. Facilitating event/activity participation, volunteering, membership

d. Analysing and improving programs, services, online offerings

e. Conducting market research and surveys

f. Complying with legal and regulatory obligations

g. Preventing fraud, crime, and unlawful activities

h. Protecting rights, property, and safety of The Million Project and others

i. Any other purpose for which you have provided explicit consent

3.2. We will only process your personal information for the stated purposes or any additional purposes disclosed to and consented by you.

4. Legal Basis for Processing

4.1. The Million Project will process your personal information based on one or more of the following legal grounds:

a. Consent: Where you have provided explicit consent.

b. Contract: Where processing is necessary for a contract with you.

c. Legal Obligation: Where processing is required by law.

d. Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, unless overridden by your interests or fundamental rights and freedoms.

e. Public Interest: Where processing is necessary for a public interest task or official authority.

5. Sharing and Disclosure of Personal Information

5.1. The Million Project will not sell, rent, or trade your personal information to third parties for marketing or commercial purposes.

5.2. We may share your personal information with trusted service providers who perform services on our behalf, such as processing donations, managing events, or providing technology services. These providers are contractually bound to protect the confidentiality and security of your personal information.

5.3. We may disclose your personal information if required by law, court order, or legal process, or if necessary to:

a. Comply with applicable laws, regulations, or legal processes

b. Enforce our policies or protect our rights and property

c. Prevent or investigate potential violations, fraud, security issues

d. Respond to emergencies involving danger to any person's life or safety

5.4. In the event of a merger, acquisition, or restructuring, we may transfer your personal information to the new entity or third parties involved, subject to appropriate confidentiality and security measures.

6. International Data Transfers

6.1. Your personal information may be transferred to and processed in countries outside of your country of residence.

6.2. When transferring data internationally, The Million Project will ensure appropriate safeguards are in place to protect your personal information, such as standard contractual clauses, binding corporate rules, or other legally recognized transfer mechanisms.

7. Data Security

7.1. The Million Project is committed to protecting the security of your personal information and has implemented appropriate technical, physical, and organizational measures to safeguard it against unauthorized access, disclosure, alteration, or destruction.

7.2. These measures include encryption, access controls, secure servers, and regular security audits and assessments.

7.3. However, no method of transmission or storage is 100% secure. If a security breach occurs that may affect your personal information, we will notify you as required by applicable laws and regulations.

8. Data Retention

8.1. The Million Project will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.

8.2. Retention periods may vary depending on the nature of the information and applicable legal or operational requirements. For example, we may retain financial data for at least seven years to comply with tax and auditing regulations.

8.3. Once the retention period has expired, or if you request erasure, we will securely delete or anonymize your personal information in accordance with our data retention policies and applicable laws.

9. Your Rights

9.1. You have certain rights regarding your personal information held by The Million Project, subject to applicable laws and regulations:

a. Right of Access: Request access to and obtain a copy of your personal information.

b. Right to Rectification: Request correction or updating of inaccurate or incomplete personal information.

c. Right to Erasure (Right to be Forgotten): Request erasure of your personal information in certain circumstances.

d. Right to Restrict Processing: Request restriction of processing your personal information in certain circumstances.

e. Right to Object: Object to the processing of your personal information in certain situations, such as for direct marketing purposes.

f. Right to Data Portability: Request a copy of your personal information in a structured, commonly used, and machinereadable format, and request transfer to another data controller where applicable.

g. Right to Withdraw Consent: Withdraw consent for processing based on consent at any time without affecting lawfulness of previous processing.

9.2. To exercise any of these rights or if you have questions or concerns, please contact us using the information in Section 13 (Contact Information).

9.3. We may request specific information from you to verify your identity before processing your request and reserve the right to charge a reasonable fee for excessive or manifestly unfounded requests.

10. Third-Party Links and Services

10.1. The Million Project's websites, applications, and communications may contain links to third-party websites, products, or services not owned or controlled by us.

10.2. This Privacy Policy does not apply to the privacy practices of those third parties. We encourage you to review their privacy policies before providing any personal information.

10.3. The Million Project is not responsible for the content, policies, or practices of any third-party offerings and denies any liability related to your use of such third-party services.

11. Children's Privacy

11.1. The Million Project's services and activities are not designed or intended for use by children under the age of 16.

11.2. We do not knowingly collect personal information from children under 16 without parental consent, except as permitted by applicable laws and regulations.

11.3. If you are a parent or guardian and believe your child has provided personal information to us without consent, please contact us, and we will take steps to remove that information.

12. Changes to this Privacy Policy

12.1. The Million Project reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or for operational, legal, or regulatory reasons.

12.2. We will post the updated Policy on our website and indicate the effective date.

12.3. If we make material changes significantly impacting how we process your personal information, we will notify you prominently on our website or by direct communication.

12.4. Your continued use of our services or websites after the effective date constitutes acceptance of the revised terms.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Data Protection Officer:

Data Protection Officer The Million Project

Aqueous International Limited, Rm B, 6/F, Real Sight Commercial


122 Woosung Street, Jordan, Kowloon, Hong Kong, 999077

+62 8133-793-1296

14. Policy Applicability and Consent

14.1. This Privacy Policy is a legally binding document that governs The Million Project's collection, use, disclosure, and protection of personal information.

14.2. By interacting with The Million Project, using our services, providing personal information, making donations, becoming a member, volunteering, or participating in our initiatives, you acknowledge and agree to the terms and conditions set forth in this Privacy Policy.

14.3. If you do not agree with the terms of this Privacy Policy, please refrain from engaging with The Million Project or providing any personal information.

15. Governing Law and Jurisdiction

15.1. This Privacy Policy and any disputes arising from or relating to it shall be governed by and construed in accordance with the laws of GDPR.

15.2. Any legal action or proceeding relating to this Privacy Policy or the handling of personal information by The Million Project shall be brought exclusively in the courts of United Kingdom, and you hereby consent to the United Kingdom of such courts.

16. Severability

16.1. If any provision of this Privacy Policy is found to be invalid, unlawful, or unenforceable, such provision shall be severed from the remainder of the Policy, which shall remain in full force and effect.

17. Entire Agreement

17.1. This Privacy Policy constitutes the entire agreement between you and The Million Project regarding the handling of personal information and supersedes all prior or contemporaneous agreements, representations, or understandings, whether written or oral, relating to the same subject matter.

Last Updated: 15 May 2024

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