1 - Introduction
Elam greatly values the partnership of all our friends throughout the world as we seek to fulfil our mission to strengthen and expand the church in the Iran region and beyond.We are committed to protecting your personal information and being transparent about what information we collect and how we use it.
2 - Scope
This policy applies to those who engage with us, whether you are a financial supporter, a prayer supporter, a visitor or user of one of our websites, or a purchaser of our resources. This policy describes the information we collect, how it is used and shared, and your choices regarding this information.
3 - Who is Elam?
Elam (“we”) is a Christian ministry that exists to strengthen and expand the church in the Iran region and beyond, with offices in the UK, the US, Australia and Germany:
Elam Ministries (“Elam UK”) is a registered charity (no. 1099143) and a company limited by guarantee (no. 4594727) in England and Wales.
PO Box 75, Godalming, Surrey, GU8 6YP, UK
Telephone: +44 (0)1483 427778
Elam Ministries, Inc. (“Elam USA”) is a 501(c)(3) non-profit charity in the United States.
5755 North Point Parkway, Suite 217, Alpharetta, GA 30022, USA
Telephone: +1 770 664 8800
Elam Ministries Australia Ltd. (ABN: 79623530889) is a company limited by guarantee and is registered as a charity with the Australian Charities and Not-for-Profits Commission.
P.O. Box 4170, Winmalee, NSW 2777
Telephone: +612 47541143
Elam Ministries e.V. (“Elam Germany”) is an association registered with the District Court of Frankfurt am Main under the following registration number: 16348.
c/o FZF Anwälte, Ludolfusstr. 2-4, 60487 Frankfurt
Elam Hellas amke ("Elam Greece") is a registered charity in Greece under the following registration number: 996766135
Mavrommateon 39, Athens, P.C. 10434, Greece
If you live in the UK, the European Union (EU), European Economic Area (EEA) or Switzerland, Elam UK is the controller of your personal information.
If you live anywhere else, Elam USA is the data controller.
4 - What information do we collect?
We only ever collect the information we need or which you agree we can collect. This includes personal information that can be used to identify you, such as your name, email address, postal address, telephone number, and bank account or payment card details. It also includes IP addresses (the location of a computer on the internet), details of pages visited on our websites and files downloaded. (Please refer to Section 11 for the lawful basis of collecting this information).
Occasionally, we may collect personal information that, in some countries, is considered sensitive or special, such as information about your health, racial or ethnic origin, political opinions, or religious or philosophical beliefs. We will only do this if there is a clear reason for doing so, such as involvement in an event where we need this information to ensure safeguarding, to carry out appropriate checks on volunteers, or care for participants. We will only use this information for the specific purpose for which you gave permission and where it is within our legitimate interests to process or where we have other legal grounds to do so.
If you are aged 16 or under, please ensure that you have your parent or guardian’s permission before giving us your personal information.
5 - How do we obtain your personal information?
We collect your personal information in the following ways:
Information that you give us directly
We collect this information in connection with specific activities. For example, when you use our websites or printed forms or telephone our offices to, amongst other things:
- make a donation
- purchase a book or other resource
- register for an event or training course
- create an account/profile on one of our websites
- engage with us on social media or our websites
- sign up for our email or print newsletters
- or otherwise provide us with personal information.
Please note: You do not have to disclose any of this information to browse our websites. However, if you choose to withhold requested information, we may not be able to provide you with certain services.
Information that we collect from your use of our websites
Website usage information is collected using cookies. This helps us to see how many people use our websites, how many people visit on a regular basis, and how frequently visited individual pages are. Cookies are also essential to our websites running correctly and delivering goods and services to users. For more information, please see our cookies policy.
Information that we receive from third parties
We may receive information about you from third parties such as event booking sites or payment processors. They will only do this if you have given your consent for them to do so. When you provide your personal information to them, you should read their privacy policies to understand how they will process your information.
Other examples might include a friend who wants to make a donation in your name; or from a delivery agent who gives us updated delivery and address information so that we can correct our records and deliver your next communication more easily.
Information that we get from public sources
We may combine information you provide to us with information available from public sources or records to gain a better understanding of our supporters and those who engage with us. This helps us to improve our communication methods, resources and programs for ministry and fundraising purposes.
6 - How do we use your information?
We use the information we collect about you to help us to fulfil our mission. This includes using your information, amongst other things:
- to process donations, orders and event bookings
- to communicate with our supporters and those who engage with us
- for administration purposes
- for internal record keeping, such as the management of feedback or complaints
- to notify you about changes to our services
- to evaluate and improve the services we offer
- to evaluate the use of our websites and ensure their content is presented in the most effective manner for you and your device (see also our cookies policy)
- to further our legitimate charitable aims such as sending you information about how donations are being used or sending you an annual report
7 - Elam’s websites and cookies
8 - Google Analytics
We use Google Analytics and other services to collect information about how our websites are used. These help us to know how often users visit our websites, what pages they visit when they do so, and how they use our content online.
9 - Links to other websites
10 - Do we share your personal information with others?
We never sell or lease your personal information with other external parties to use for their own purposes.
There are scenarios where we may share your personal information with an external party. These include:
- Where we run an event in collaboration with another external party, your personal information may need to be shared with them and those who provide services to help us deliver the event. Where we are required to do so, we will make it clear what will happen to your personal information when you register.
- Where we employ a third party to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, evaluating data, providing marketing assistance, processing credit card payments, and providing customer service. We will give them access to the personal information needed to perform their functions, but they may not use it for other purposes. We require them to comply strictly with our instructions and data protection laws and will make sure that appropriate controls are in place.
- Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies), or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect us (for example in cases of suspected fraud or defamation).
11 - What is our lawful basis for processing your personal information?
We will only collect and process personal information about you where we have a lawful basis to do so under applicable laws. The lawful basis will depend on the reason or reasons we collected and need to use your information, and which of our entities is the data controller. In most cases, the lawful basis will be one of the following:
- Consent - you have given your consent for us to use your personal information for a particular purpose, such as sending you our email newsletters.
- Contractual - we need to use your personal information to fulfil a contract we have with you, such as processing a donation or order.
- Legal obligation - we need to use your personal information to comply with a legal obligation, such as claiming Gift Aid on donations in the UK.
- Legitimate interest - we have a legitimate interest to use your personal information to fulfil our charitable objectives, and these interests do not override your rights.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).Where we rely on your consent to process your personal information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
If you have any questions about the lawful bases upon which we collect and use your personal information, please contact us.
12 - How do we keep your personal information secure?
We place great importance on the security of your personal information. We have strict procedures and security features in place to protect your personal information and prevent unapproved access, disclosure, use and modification (such as locked cabinets, data encryption and electronic password protection), although we cannot completely guarantee its security.
We have contracts in place with third-party service providers acting as data processors for us that have access to your personal information, to ensure that the required level of security is in place, and that your personal information is processed only as instructed by us.
Where you or we have provided a password enabling you to access parts of our websites or use our services, it is your responsibility to keep this password confidential. Please do not share your password with anyone. If you think anyone else has gained access to your password, please let us know as soon as possible.
International data transfers
If you use your credit or debit card to donate to us, buy something or pay online or over the phone, we will ensure that this is done securely.
Only those people permitted to process payments will be able to see your card details. Once your transaction is completed, we do not retain your full credit or debit card details.
13 - For how long do we keep your personal information?
We will keep personal information only for as long as we need it to maintain our relationship with you, provide you with the products, services or information you requested, to inform our research into the preferences of our supporters, to comply with the law, and to ensure we do not communicate with individuals that have asked us not to. When we no longer need the information, we will dispose of it securely, using specialist companies to do this work for us if necessary.
14 - What rights do you have regarding your personal information?
For personal information that we have about you:
- Delete Data: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide services to you or we are not legally obliged to retain it).
- Change or Correct Data: You can edit some of your personal information through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
- Right to Access and/or Take Your Data: You can ask us for a copy in machine readable format of your personal data.
We will not use your information for marketing or fundraising purposes if you have asked us not to or we are not legally allowed to use it for these purposes. (In certain circumstances we must obtain your permission before we contact you for marketing or fundraising purposes.) However, we will retain your basic details on a suppression list to help ensure that we do not continue to contact you.
If you are registered to receive our email newsletters, you will be given a clear opportunity to opt out of/unsubscribe from future email communications.
You may also have additional rights, depending on where you live. For example, if you live in the EU, EEA or Switzerland (where Elam UK is the data controller), you may ask us to explain any automated processing we carry out and the impact of this on you, or you may raise a concern or complaint with the UK Information Commissioner’s Office (ICO) about the way your personal information is being used. For more information, visit www.ico.org.uk.
15 - Complaints, compliments or comments
We want to know if you are unhappy with our work or something that we have done or failed to do. We also welcome your views on what we do well. Your comments help us learn and continuously improve our services. You can get in touch with us here.
We keep this policy under regular review. If we make any significant changes in the way we treat your personal information, we will make this clear on our websites or by contacting you directly.
Details of the sections of the policy that have been changed will be noted here.
On 7 October 2019, the details of 'Elam Germany' were added to section 3 of this Privacy Notice.
This policy replaces any and all previous versions and is effective from 7 October 2019.