HOW WE COLLECT INFORMATION

Swab The World has created this Privacy Policy to explain how it collects, uses, discloses and safeguards Personal Information in connection with the use of the Website.

We may collect Personal Information from a variety of sources, including:

· directly from you
· from Swab The World Partners
· automatically, from devices used to connect to the Website

INFORMATION WE COLLECT

Personal Information collected may include:
· For all Visitors : contact information provided by you, Internet Protocol address, de-identified site behavior information.
· For Patients, Survivors and Donors: information provided by filling a consent form, including e-mail address, birth year, ethnicity, country of residence, status as a patient, illness, transplant date, donation date, social media link, photo or video.
· other information you choose to provide

HOW WE USE INFORMATION

We use Personal Information we collect to:

· operate the Website and personalize Visitors’ experience on the Website
· analyze the use of and improve the Website
· comply with applicable laws and Swab The World’s policies
· provide the Service

HOW WE SHARE INFORMATION

Swab The World may share Personal Information it collects:

• in connection with the operation of the Website
• in connection with provision of the Service
  
• for law enforcement

WEBSITE INTENDED USERS

THE WEBSITE IS INTENDED FOR USE BY YOU ONLY.

This Privacy Policy shall be reviewed carefully as it governs the use of the Website.

Swab The World may change this Privacy Policy from time to time. Should you object to any changes made, you shall stop using the Website. By continuing to use the Website after the amendment of this Privacy Policy, you will be deemed to adhere to its terms, as amended.

You may contact us if you have any questions about this Privacy Policy.

GENERAL PRINCIPLE

Swab The World is committed to protecting the privacy of Personal Information. In order to bring to your attention the privacy practices implemented, Swab The World has prepared this Privacy Policy, which summarizes: (i) the types of Personal Information collected, (ii) why it collects Personal Information, (iii) how it uses and protects Personal Information, and (iv) under what circumstances Personal Information is shared with its Partners and other third parties when required or permitted under applicable law. This Privacy Policy further describes the decisions that can be made with respect to the collection, access, use and storage of Personal Information.

This Website’s Personal Information is controlled by:

Swab The World Foundation
200-358 Beaubien Street West
Montreal, QC H2V 4S6

[email protected]

DEFINITIONS AND INTERPRETATION

In this Privacy Policy, the terms set forth below have the following meanings:

• Cookies designates the small text files that are placed on the hard disk of devices when someone accesses the Website, which may either be temporary and disappear when such devices are turned off or be permanent and stay even after such devices are turned off.
• Donor designates any person having completed stem cell donation who voluntarily provides information to Swab The World through its Website to access the Service.
• Patient designates any person in treatment for blood cancer or blood disorder with no donor who voluntarily provides information to Swab The World through its Website to access the Service.
• Personal Information means any information about an identifiable individual, including but not limited to contact information, address, e-mail address, photo or video, Internet Protocol address, birth year, ethnicity, country of residence, status as a patient, illness, transplant date, donation date and social media link.
• Swab The World designates Swab the World Foundation / Mai Duong Foundation.
• Swab The World Partners designates the business partners assisting Swab The World in the development or operation of the Website, such as, but not limited to: (i) Facebook, LinkedIn, Instagram, Twitter and other social media offering marketing or promotional tools and platforms , (ii) SiteGround, providing servers location and cloud computing platforms for the storage of various information (including Personal Information), (iii) WooCommerce, providing e-commerce and merchandizing services; (iv) Stripe, providing fundraising and donation services, (v) MyFonts, providing font hosting services, (vi) Google Analytics, providing site visitation analytics services, (vii) Google Ads, providing advertising services on behalf of Swab the World.
• Service means, collectively, the Website, the Swab the World platform and services provided on the Website
• Survivor designates any person having received a stem cell donation or otherwise survived blood cancer who voluntarily provides information to Swab The World through its Website to access the Service.
• Visitor means any person browsing on the Website.
• Website means website available at https://swabtheworld.com and all its subdomains, as may be applicable from time to time.

Unless the context requires otherwise: (i) grammatical variations of any term defined herein have a similar meaning; and (ii) words importing the singular number shall include the plural and words importing the masculine gender shall include the feminine and neutral genders and vice versa.

COLLECTION AND USES MADE OF PERSONAL INFORMATION

In the course of operating the Website, Swab The World will collect and/or process information about you, as described below. Swab The World also collects information about any Visitor when such Visitor accesses the Website or otherwise contacts Swab The World to enquire or make comments about the Website. In all cases, such Personal Information is only collected and used for the purposes detailed in this Privacy Policy and for no other purposes.

Use of Personal Information must be justified in accordance with applicable law. An explanation of the scope of the legal justifications available can be found in the following:

Consent: where you have consented to our use of your Personal Information (you will have been presented with a consent form in relation to any such use and may withdraw at any time).

Contract performance: where your Personal Information is necessary to enter into or perform our contract with you.

Legal obligation: where we need to use your Personal Information to comply with our legal obligations.

Legitimate interests: where we use your Personal Information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your rights.

Legal claims: where your Personal Information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

Creation of online accounts

A user’s account will need to be created in order for you to access all the functionalities of the Website.

In order to create such a user account, you will be required to disclose to Swab the World the following Personal Information: your name and surname, username name, an email address and your birthday. The foregoing information is required to create your unique user account and to authenticate you each time you sign in.

Use justification: contract performance, consent

Information obtained directly from Patients, Survivors and Donors

Swab The World collects Personal Information that is voluntarily provided to it when Patients, Survivors and Donors use the Service offered on its Website. Use of the Service is voluntary, and Patients, Survivors and Donors choose the information they submit to Swab The In order to use the Service, they will be required to provide some or all of the following information: e-mail address, birth year, ethnicity, country of residence, status as a patient, illness, transplant date, donation date, social media link, photo or video. This information is required by Swab The World in order to provide the Service. It may be reviewed, amended and shared with Swab The World Partners as needed in providing the Service.

Use justification: consent

Comments and requests for information

Should you or any Visitors contact Swab The World to obtain information about the Website or about any other matter, then you or any Visitors will be required to provide your/their contact information (including names and e-mail addresses). This information is required by Swab The World in order to communicate with you and respond to your enquiries, comments or requests for information. You or Visitors may also provide additional Personal Information, including when making comments, enquiries or suggestions.

Use justification: legitimate interests, consent

Marketing

Swab The World may wish to provide information about its Website or the Service. In this regard, Swab The World may use the e-mail address or other contact information any person may provide from time to time to provide information about new features or services or to send news and information regarding the Website, e.g. by registering for our newsletter. Such communications will be sent in accordance with applicable laws. Such person may withdraw his/her consent at any time as set forth below. Note that Swab The World does not sell or share Personal Information to third parties for third party marketing purposes.

Use justification: legitimate interests, consent

Social media

Swab The World shares information about itself, its Website and its Service on Facebook. Similarly, if any person sends or accepts Swab The World’s “friend request” or otherwise “follows” Swab The World, then such person will share and Swab The World may consult the information that he/she and their “Facebook friends” posted on their Facebook pages. Since users can always choose the audience that can see what they share via their Facebook privacy settings or the Facebook audience selector, any person is deemed to have agreed to share such information with their “friends” or persons they “follow”, including Swab The World as described in Facebook privacy policy and terms of use.

Other social media platforms such as Twitter, Snapchat, LinkedIn and Instagram will also allow any person to follow Swab The World and to add Swab The World to their contact list. In such a case, Swab The World will have access to such person’s web pages and profiles in accordance with the chosen settings, as more fully described in the privacy policies and terms of use of these social media operators. Swab The World will also get notification and access to any tweet, link or post in which Swab The World is tagged.

Any person shall review the privacy settings applicable to these accounts/pages to see the information to which his/her contacts have access and limit such access if required. Should Swab The World collect information available on social media accounts or pages, it shall do so on an aggregate and de-identified basis and for lawful purposes only.

Use justification: legitimate interests, consent

Testimonials and promotional materials

Should you or any other person wish (or agree) to render any testimonial, opinion, photo or any other material available online regarding your/their appreciation of the Website, then Swab The World may post such promotional materials on its Website or any other social media, and may include your/their name or nickname and any other information you/they agreed to disclose. You/that person can thereafter request, at all times that such materials or other Personal Information be removed from the Website and any other social media. Swab The World does not however control the communications – if any – that you/such person may receive in connection with any promotional materials. Should you or any person wish to report any communication received regarding such promotional materials or other information, then you/such person should contact Swab The World as described below.

Use justification: consent

Information obtained from Swab The World Partners

Swab The World Partners may collect information about you or any other person as follows:

• Google Analytics: Google analytics will collect data about your or any visitors’ interactions with the Website. In order to do so, Google Analytics will place codes on the Website, which will allow Google Analytics to see which information was consulted, the browser used, device and operating device used. Such information will then be processed and will be updated each time you or any Visitors interact with the Website.
• WooCommerce: WooCommerce will process e-commerce orders and share shipping and order information with Swab The World. Such information is then used to send merchandize sold through the Website. The WooCommerce privacy policy may be viewed at https://automattic.com/privacy/.
• Stripe: Stripe is a third party payment processor to process donations made to Swab The World. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed at https://stripe.com/us/privacy.

The information so collected may be shared (in whole or in part) with Swab The World in order for Swab The World to update, upgrade or otherwise improve the Website, or to develop new services.

Use justification: legitimate interests, consent

Information collected using Cookies

When you or any Visitors navigate the Website, certain information, including Personal Information (such as general browser information, Internet Protocol addresses, the interactions with the Website and any other information described below) may be collected by the following Cookies:

• Process Cookies: allow the Website to work properly in keeping track of requests, ensuring the integrity of web pages and allowing you and Visitors to browse from one page to the other.
• Security Cookies: are used each time an account is opened. These Cookies contain an encrypted, unique identifier that is tied to each account and placed in the browser, allowing Swab The World to identify you when you are logged into your account.
• Statistical Cookies: collect data, such as the date and time when the Website was last used and the frequency of such uses, the pages or content consulted and the manner the Website was used, the information provided and the features of their operating systems and connection information (e.g. Internet Protocol address). This information is collected for analytical and statistical purposes, such as to determine how often the Website or certain specific pages are visited, and what kinds of features and content seem to be most interesting. It may also be used to retarget Visitors in advertisement or communications. This information helps Swab The World to improve its Website, according to the needs and interests identified.
• Advertising Cookies: we allow certain companies to collect information from browsers of our website to serve interest-based ads. These companies are usually third party ad servers used by media companies, technology vendors or providers of sponsored content. Using cookies and web beacons, these companies collect data from a particular browser and use such data to predict user preferences and to deliver advertisements. This helps Swab The World bring more qualified visitors to the website.
• You or any Visitors, as applicable, can block Cookies unless they are required to allow the Website to run properly. For instance, while statistical Cookies can be blocked, the situation is different for process and security Cookies, as they are essential for ensuring that the Website function properly. However, even if they cannot be blocked without affecting one’s ability to use the Website, these Cookies are of a temporary nature and accordingly, they will disappear when the browser software is closed or the device is turned off. Anyone experiencing problems with the functionalities of the Website should contact Swab The World.
  
  Use justification: legitimate interests, consent

SHARING OF PERSONAL INFORMATION COLLECTED

Swab The World does not sell or rent Personal Information. Furthermore, Personal Information is not shared, traded, used or disclosed to third parties for purposes other than those for which it was collected as described herein, unless required or authorized by law or unless proper consent was obtained, as applicable.

Personal Information

Sharing made in connection with provision of the Service

Personal information may be disclosed to Swab the World Partners that facilitate the provision of the Service, such as social media platforms allowing visibility of Patients and matching of Patients with potential donors.

Sharing made in connection with the operation of the Website

Personal Information may be disclosed to Swab The World Partners that facilitate the operation of the Website, such as by providing assistance to Swab The World with respect to the maintenance and development of its Website. Disclosure will be made on a “need-to-know” basis, and after ensuring that proper contractual and other measures are in place.

Law enforcement

Personal Information may be used and disclosed if Swab The World, acting reasonably, believes that such use or disclosure is necessary to comply with any applicable laws, legal process or governmental request, or is otherwise required to protect its rights or to fulfil any other purpose set forth in the applicable law allowing or requiring the disclosure of Personal Information.

Anonymous Information used on an aggregated basis

Swab The World may use Anonymous Information on an aggregated basis in order to improve the Website. Anonymous Information may also be used for training, promotion, research and statistical purposes and any other purposes, as such information does not constitute Personal Information. In any event, note that such information could not and will not be used to re-identify You or any other individual.

ACCESSING, CORRECTING AND UPDATING PERSONAL INFORMATION AND YOUR RIGHTS AS A DATA SUBJECT

Requests from you

In accordance with applicable laws, you may make requests for access or for corrections of Personal Information by contacting Swab The World.

Your rights pursuant to the EU General Data Protection Regulation (GDPR)

To the extent the GDPR applies to data processing activities, i.e processing of personal data of data subjects who are in the EU, you have certain rights, which we will inform you about below:

1. Right to information: You have the right to request a copy of the personal data collected about you.
2. Right to rectification: You have the right to request the completion or rectification of incorrect personal data concerning you if it is incorrect or incomplete.
3. Right of deletion: If there are certain reasons, you can request the deletion of your personal data. However, this only applies when we no longer need your data to fulfill contracts with you.
4. Revocation of consent: In general, we only process your data to fulfill the contract and do not ask for your consent for any further processing. If you have nevertheless given us your consent to further processing of your personal data in individual cases, you can revoke this consent and prevent further data processing, provided that no other justification is relevant. This right of revocation does not apply to the data that we store for the purpose of fulfilling the contract.
5. Right to limitation of processing: You may request the restriction of the processing of certain personal data for the duration of a complaint procedure or for specific other reasons.
6. Right to data portability: You may request that we transfer electronically your personal data that you have provided to us and which we have still stored to another person in charge.
7. Right to complain: You can complain about our data processing to us or to the competent data protection authority.

Please note that there are exceptions to the above rights and that you cannot exercise these rights in every situation.

SECURITY MEASURES IMPLEMENTED

Swab The World uses measures as may be reasonably required to preserve the security and privacy of Personal Information. In this regard, Swab The World has notably put in place or currently implements the following measures:

SSL technology: Each time the Website is accessed via Internet, Secure Sockets Layer (SSL) technology protects Personal Information by using server authentication and data encryption. No Personal Information will be communicated prior to this technology being activated, which can be confirmed by looking (i) at the address bar which will, depending on the browser, have a lock to the left of the Website address (URL), and (ii) at the URL or the address bar of the browser, where the first characters of the address in that line should change from “http” to “https”.

Limited access: Access to any Personal Information is granted to Swab The World’s employees, representatives and as applicable sub-contractors on a “need-to-know” basis only.

Secured center: Swab The World’s platform and servers are located in data centers located in the United States and Swab The World’s Website are currently being hosted at SiteGround. Additional information regarding these hosting services can be obtained by reviewing SiteGround “Terms and Policies” page available here https://www.siteground.com/terms.htm, as of the effective date of this Privacy Policy (as may be amended from time to time or rendered available via other hyperlinks).

Despite the foregoing, you and any other person shall be aware of the following:

GENERAL CONSIDERATIONS: EVEN IF SWAB THE WORLD USES TECHNOLOGIES, WHICH ARE OF MERCHANTABLE QUALITY SUITABLE FOR THE OPERATION OF THE WEBSITE, ANY ELECTRONIC PLATFORMS AND SERVERS – AS with ANY OTHER FORM OF file – IS NOT INFALLIBLE AND FULLY SHELTERED FROM UNFORESEEABLE OR FORCE MAJEURE EVENTS, CYBERATTACKS OR UNAUTHORIZED USES AND ACCESS, AND YOU AND any OTHER PERSON shall BE AWARE THAT THERE IS A RISK IN TRANSMITTING ANY DATA ELECTRONICALLY. THIS RISK IS INHERENT IN ALL ELECTRONIC DEALINGS, AS WELL AS TO ALL OTHER FORMS OF COMMUNICATIONS. CONSEQUENTLY, SWAB THE WORLD CANNOT GUARANTEE THAT INFORMATION WILL NEVER BE INTERCEPTED OR VIEWED OR SUBJECT TO OTHER INCIDENTS. such events may occur, pursuant to which devices or systems can be accessed or controlled by unauthorized persons, and undesirable COMMUNICATIONS AND invitations may be received. Should You or any PERSON receive a communication that looks like it is from SWAB THE WORLD asking for Personal Information, You or such person shall avoid responding to such communications. SWAB THE WORLD will never request financial and other sensitive information that way. If You or any PERSON have communicated Personal Information in response to a suspicious e-mail, pop-up or phony website claiming to be affiliated with SWAB THE WORLD or if any of the foregoing events takes place, please contact SWAB THE WORLD immediately.

STORAGE OF PERSONAL INFORMATION

Subject to applicable laws, Swab The World shall retain and store Personal Information for use and disclosure consistent with this Privacy Policy, as long as necessary for the purposes detailed herein. To that end, Swab The World may retain Personal Information after a specific purpose has been fulfilled if reasonably necessary: (i) to comply with applicable laws or prevent any contravention; (ii) to resolve disputes; and (iii) to enforce this Privacy Policy. Once no longer required, the information will either be erased or stored on an aggregated and de-identified basis.

THIRD-PARTY WEBSITES

Should any link to third-party websites (including national registry websites) be provided on the Website, then you and any other person shall be aware that these sites operate independently, and are subject to distinct terms of use and privacy policies. It is strongly recommended that you and any other person as applicable, review the distinct terms of use and policies of such third-party websites, as Swab The World is not responsible for the content or practices of any such websites.

CONTACTING SWAB THE WORLD

Questions, comments and requests

All questions and comments regarding this Privacy Policy or requests made in furtherance of said policy should be directed to Swab The World: https://swabtheworld.com/about/contact-us/.

Requests and demands made will be dealt with as soon as possible.

Withdrawal of consent

Swab The World may communicate with you or with any Visitor for promotional and marketing purposes. Swab The World will generally use the same means of communication you or such Visitor chose to contact Swab The World or the preferred means specified by you or that Visitor. Should you or said Visitor wish to be removed from one or more of Swab The World’s promotional mailing lists, then you or that Visitor should click on the ready-to-use “unsubscribe” mechanism provided at the bottom of each e-mail, or request to be unsubscribed by contacting Swab The World at https://swabtheworld.com/about/contact-us/

CHANGES TO PRIVACY POLICY

Swab The World reserves the right to change or modify this Privacy Policy from time to time. Any material change will be notified prior to the change taking effect via a web banner or by any other means. Thereafter, the Privacy Policy as updated will be made available and easily accessible. Furthermore, an updated version of this Privacy Policy will be published each time a minor change is made. Anyone may determine whether this Privacy Policy has changed by looking at the effective date appearing at the top of said Privacy Policy. Swab The World recommends that this Privacy Policy be reviewed periodically in order to assess Swab The World’s current practices, as the continued use of the Website shall constitute acceptance of any amendment thereto. Should you, disagree with the amendments made to this Privacy Policy or other applicable terms and conditions, you shall immediately stop accessing or using the Website.