1. WHO WE ARE
The Plastic Oceans International (POI) is a charitable organization dedicated to raising awareness on the issue of plastic pollution and on solutions to the problem. We are registered in the United States as a non-profit organization with 501(c)3 status; and we operate under the laws of the State of California. Our federal Tax ID number is #81-3778043.
2. DATA PROTECTION
POI takes data protection very seriously and is committed to protecting your privacy and security. This policy explains how and why we use your personal data.
As you browse our website and whenever you communicate with us, we collect information. This deepens our understanding of what you are interested in, and helps us improve the efficiency of our work and fundraising communications. The more information we have, the more efficiently we are able to operate and the more funds we can direct into activities that allow us to achieve our mission and goals.
POI takes great care to preserve your privacy and safeguard any personal details you provide to us, and we will never exchange or sell your information to another organization unless you give us your permission. We know that this is important to you and want to reassure you that you are always in control of how we use your personal information for marketing and fundraising activities.
Plastic Oceans International
23823 Malibu Road Ste 50-205
Malibu, CA 90265
(310) 974-3038 (between 9am – 5pm PT, Monday – Friday)
3. WHAT INFORMATION DO WE COLLECT?
We collect and use your personal information for carefully considered and legitimate charitable business purposes that help ensure we can run POI efficiently, raise funds effectively and deliver our charitable objectives. This policy sets out how we use your personal data, what data we collect, and the legal basis for its use and outlines your rights in respect of your personal data.
Personal data you give us
We collect personal data you provide us with when joining our newsletter, making a donation, or applying for a screening of a film. For example:
- Email address when you join our mailing list. No other data is collected for this.
- Personal details when you make a donation: name, mailing address, phone number, email address.
- Personal details when you apply to host a screening of a film: name, email address, name of your organization (if applicable), basic details about the event/screening that you would like to host. This information is not saved to a database, but rather is mailed to our screenings manager, who in turn would contact you directly to provide you the information that you are requesting.
- Financial information when you choose to make a donation (payment information such as credit/debit card or direct debit details, and whether donations are gift-aided; and
Information created by your involvement with POI
Your activities and involvement with POI will result in personal data being created, including details of how you have helped us by volunteering or being involved with our campaigns and activities.
If you donate to us then we will keep records of when and how much you gave to a particular appeal or campaign.
Information we generate
We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analyzing your location and involvement with our work we would hope to build a profile to help us decide which of our communications are likely to interest you.
Information from third parties
We may also receive information about individuals from third parties. This can include information such as your name, address, credit/debit card details and whether you are a taxpayer so that we can claim a tax deductible donation.
We use social media platforms for engaging with our supporters, such as Facebook, Instagram and Twitter. As a result, we collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.
Sensitive personal data
We do not normally collect or store sensitive personal data (such as information relating to health, race, religious beliefs or political opinions) about supporters and members. However, there are some situations where this may occur to ensure we provide appropriate facilities (for example, if you wish to participate in an extreme running or kayak challenge event). If this does occur, we’ll take extra care to ensure your privacy rights are protected.
If you are a volunteer then we may collect extra information about you (for example, references, details of emergency contacts, medical conditions etc.). This information will be retained for legal reasons to protect us (including in the event of an insurance or legal claim) and for safeguarding purposes.
4. HOW WE USE INFORMATION
We always strive to provide a clear, honest and transparent approach regarding how and when we collect and use your personal data, we’ll only use your personal data where you would expect us to do so and we’ll only use your information for the purpose or purposes it was collected for, including as follows:
We use personal data to communicate with people and to promote POI. This includes keeping you up-to-date with our news, updates, campaigns and ways you can help fundraise. For further information on this, please see Section 6 (Marketing).
We use personal data for administrative purposes (i.e. to carry out our charity and conservation work). This includes:
- receiving donations such as direct debits;
- maintaining databases of our volunteers, members and supporters;
- fulfilling orders for goods or services (whether placed online, over the phone or in person);
- helping us respect your choices and preferences. If you ask not to receive marketing material, we’ll keep a record of this.
Internal research and analysis
We carry out internal research and analysis using the data provided by our supporters, donors and volunteers, to determine the success of campaigns and appeals, better understand behavior and responses and identify patterns and trends. This helps inform our approach towards campaigning and makes POF a stronger and more effective organization. Understanding our supporters, their interests and what they care about also helps us provide a better experience (e.g. through communications that are more relevant.)
We evaluate, categorize and profile personal data in order to tailor materials, services and communications (including targeted advertising) so that we only send you information you may be interested in. This also helps us understand our supporters and improve our organization.
We profile supporters in terms of recency, frequency and value of financial and non-financial support. This information helps us to ensure communications are relevant and timely.
If, based on information that has been provided to us (such as zip code, demographics, or previous donations), it appears supporters might be willing and able to provide more assistance in our fight to save our seas, we may contact them to see if they wish to do so.
In the future, we collect information on preferences and interests (for example, whether you have an interest in beach cleanups or film screenings) so that we know what material you are mostly likely to be interested in.
We may aggregate and anonymize personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as recruiting new supporters, or to identify trends or patterns within our existing supporter base. This information helps inform our actions and improve our campaigns, products/services and materials.
5. DISCLOSING AND SHARING DATA
We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our partners, or third party products and services, but these communications will always come from POI and will normally be incorporated into our own marketing materials and communication efforts.
Occasionally, where we collaborate with other organizations, we may also share information with them (for example, if you register to attend an event being jointly organized by us and another charity). We will only share information when necessary and we’ll make sure to notify you first.
Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
You can set your browser to not accept cookies; each browser provider will have information on how to do this. In a few cases some of our website features may not function correctly as a result. We use Google Analytics to help us understand how our website is performing and to collect data about traffic through our website via Google advertising cookies and anonymous identifiers. In addition to data collected through a standard Google Analytics implementation, POI uses the following advertising features: Search advertising with Google Adwords.
POI will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through any Google advertising product or feature unless there is robust notice of, and the user’s prior affirmative (i.e., opt-in) consent to, that merger. You can prevent Google from recording the data generated by the cookie in relation to your use of the site (including your IP address) and from processing this data by downloading and installing the browser plug-in available via the following link: https://tools.google.com/dlpage/gaoptout.
POI asks its supporters to “opt-in” for most communications, including all our E-marketing communications (the term marketing is broadly defined and, for instance, covers information about conservation, fundraising and other POI news).
You have the choice whether you want to receive these messages and be able to select how you want to receive them (post, phone, email, text).
You can decide not to receive communications or change how we contact you at any time. If you wish to do so, please contact us via the information provided in section #1 above.
What do we mean by ‘marketing’?
Marketing does not just mean offering things for sale, but also includes news and information about: – our charity, campaigns and conservation work; – educating the public on plastic pollution and related topics (ocean literacy); – volunteering opportunities and how you can help us with our work; – taking part in beach cleans; – our events, activities and local groups; – appeals and fundraising (including donations and competitions).
When you receive a communication from us, we may collect information about how you respond to or interact with that communication, and this may affect how we communicate with you in future.
Fundraising and marketing
As a charity, we rely totally on individual donations, grants, corporate giving and support from others to undertake our work. From time to time, we will contact members and supporters with fundraising communications. These might be about an appeal, a contest or promotion we’re running, or to suggest ways you can help raise funds (for example, a sponsored challenge event, or buying a product if POF will receive a percentage of the proceeds).
We are totally dependent on the generosity of our supporters, whether to sign a petition to help us lobby during a campaign, or to respond to an appeal to raise vital funds for the charity to continue to be voice for our seas. All our work requires us to communicate with our supporters to let them know what actions they can take. We call these marketing communications.
7. CHILDREN AND YOUNG PEOPLE
If your child is under 18 then we’ll need permission from you as their parent or guardian for them to enter one of our competitions or to share a picture, photo or story with us.
Photographs, pictures and stories in our Social Media and on our Website
We want young people to join in saving our seas, and sometimes there are opportunities for sharing photos, stories and pictures. We ask consent prior to publishing any child’s picture, photo or story; this may include also publishing their name and age if appropriate. We will only proceed in using images once consent has been provided in writing. Even if consent has been given, you can at any time change your mind and request that any photos be taken down. Photos will be removed from any public communication within 48 hours of a written request being made.
POI will state in age-appropriate language that children must only enter the competition if they have permission from their parent first. We will make reasonable efforts to verify that consent has been given or authorized by the holder of parental responsibility and treat all the identifiable submitted competition materials, including names, ages and other details as personal data.
If your child enters a competition and is one of the lucky winners or runners-up, we’ll publish their name and winning entry alongside the other winners.
Information for parents
We take great care to protect and respect the rights of individuals in relation to their personal data, especially in the case of children. If your child is under 18, we’ll only use his or her personal data with your consent. This means that, for example, if your child wants to have his or her name or picture featured on our website, in social media or in our email newsletter.
Marketing and fundraising
We won’t knowingly send marketing emails, letters or messages to under 16 year-olds and, in order to order items from our online shop, you need to be an adult.
8. HOW WE PROTECT DATA
We use various physical and technical measures to keep your personal data safe and to prevent unauthorized access to, or use or disclosure of your personal information. Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive internal data protection training and we have a set of detailed data protection procedures which staff are required to follow when handling personal data.
All electronic forms that request financial data on our behalf use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.
If you use a credit card to donate, purchase or rent a film, your credit card details are securely transmitted via our payment providers (Qgiv for donations; and VHX for film rentals and purchases). POF complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council, and will never store card details.
Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (for example, information provided by email or our website) are at the user’s own risk.
Where we store information
POI’s operations are based in the USA and we store our data within the United States. Some organizations that provide services to us may transfer personal data outside the USA, but we will only allow them to do this if your data is adequately protected.
How long we store information for
We will only use and store information for as long as it is required for the purposes for which it was collected. How long this will be depends on the type of information and how it is used. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (although we will keep a record of your preference not to be emailed).
We continually review what information we hold and delete what is no longer required. We never store payment card information.
10. DATA PROTECTION RIGHTS
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as a subject access request);
- the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason);
- the right to have inaccurate data rectified;
- the right to object to your data being used for marketing or profiling; and
- where technically feasible, you have the right to see the personal data you have provided to us that we process automatically based on your consent or the performance of a contract.
Please keep in mind that there are exceptions to the rights above and, although we will always try to respond to your satisfaction however, there may be situations where we are unable to do so.
If you would like further information on your rights or wish to exercise them, please contact us via the information provided in section #1.
Please do not hesitate to contact us with any complaint that you have. We are always happy to directly address any and all concerns that you have. If you do have a complaint, please contact us via the information provided in section #1 and will will respond within 72 hours.
11. LINKS TO OTHER SITES
Links to other sites
Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the ‘Contact us’ link at the bottom of the page).
When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with POF.
12. Your California Privacy Rights
Notice to California Residents
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in Privacy Statement of Plastic Oceans International and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Personal Information that We Collect, Use and Share
Here is a summary of how we currently collect, use and share personal information, and how we have collected, used and shared the information within the last 12 months.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected some of the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||Real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Physiological, biological and behavioral characteristics, including DNA, that can be used to establish individual identity, such as iris or retina images, fingerprints, faceprints, and voiceprints, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information regarding a consumer’s interaction with an Internet website, application, or advertisement.||YES|
|G. Geolocation data.||Precise location, e.g., derived from GPS coordinates or telemetry data.||YES|
|H. Sensory information.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Past or current employment history and performance evaluations.||YES|
|J. Non-public personally identifiable information (as defined by FERPA).||Name, address, other indirect identifiers such as date and place of birth or mother’s maiden name, and other information that is linked or linkable to a person (most likely, a donor) to enable a third party to identify the student.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly and indirectly from our clients or their agents.
- Directly and indirectly from consumers, such as prospective or current students. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly through business partners, such as colleges and universities we work with.
- Directly and indirectly from activity on our website (https://plasticoceans.org). For example, from submissions through our website portal or website usage details collected automatically.
- From third parties that interact with us in connection with the services we perform, such as data brokers.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information to make a donation, we will use that information to send to our current donation platform, Qgiv, so they can process your donation.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the last 12 months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Potential students.
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the last months, we have not sold any personal information, other than sharing learner information with our academic partner institution if needed for enrollment or transcript purposes. Please note that the CCPA defines sale broadly, and yes, when we send your information to University of California so you can get a grade or a transcript, California law calls that a “sale” although for normal people, that wouldn’t be a sale at all – it is simply to make sure you get proper credit and record of your work. As a result, even when we do not get paid for the information and the recipient uses the information for its own purposes, the mere disclosure of the personal information to the recipient may be considered a sale under the CCPA.
Your Privacy Rights
You have the following rights under the CCPA:
Access to Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- 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 or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion is likely to render impossible or seriously impair the achievement of this research, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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 either:
- Emailing us at email@example.com, or
- Visiting https://plasticoceans.org
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, 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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows 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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (310) 974-3038 (between 9am – 5pm PT, Monday – Friday)
Postal Address: Plastic Oceans International, 23823 Malibu Road Ste 50-205, Malibu, CA 90265