Important information and who we are:

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Project Pink (the “Charity”) is a registered Bermuda charity focused on breast cancer support, research, and education and is committed to protecting the privacy and security of its supporters, donors, volunteers, and individuals impacted by breast cancer in Bermuda in accordance with the Personal Information Protection Act 2016 (the “PIPA Act”).

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This privacy policy aims to outline how the Charity collects and processes your personal data ensuring compliance with the PIPA Act and applicable privacy laws.

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This policy applies to all personal information collected, used or disclosed by the Charity, including but not limited to:

• Donors and supporters;

• Volunteers and event participants;

• Individuals seeking support or information; or

• Employees, third-party service providers and contractors.

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Our website is not intended for children, and we do not knowingly collect data relating to children through the use of our website.

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It is important that you read this privacy policy together with any other privacy policy or data processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any other policy and is not intended to override them.

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Controller

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Commitment to Privacy

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The Charity as the controller of your data is committed to protecting your privacy, while providing you with the opportunity to receive our services. The Charity may collect information relating to you as an individual (including certain sensitive personal information, where permitted by law (your “Personal Information”). The policy outlines how we collect, use, disclose, and safeguard personal information related to the support, research, and education we provide.

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We have designated an individual to be responsible for compliance with this Privacy Policy and have adopted procedures to protect Personal Information, receive and respond to complaints and inquiries, train staff regarding policies and procedures and communicate our policies to you. We will monitor ongoing developments in privacy legislation and make changes to this policy as required.

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You have the right to make a complaint about how we manage your personal data to the respective supervisory authority. We would, however, appreciate the chance to deal with your concerns before you do, so please contact us in the first instance.

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Your duty to inform us of changes

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It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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Third-party links

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Our website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

The data we collect about you

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Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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In addition to personal information provided to us by you through our volunteers or website, we may also collect information that is publicly available. The personal information we may hold includes, but is not limited to:

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• Full Name;

• Contact information (e.g., phone number, email address, mailing address);

• Donation details (e.g., amount, method of payment);

• Participation in events or programs (volunteer details, event registration and preferences); 

• Compliance with legal and regulatory obligations;

• Communication preferences;

• IP addresses; or

• Details related to marketing our services, education material, our breast cancer awareness campaigns in addition to including recording your usage of our website, social media platforms and any mailing lists for which you have subscribed or unsubscribed.

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Personal information will be collected directly from the individual unless otherwise authorized by law.

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Limits on Collection, Use, Retention and Disclosure of Personal Information

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The Charity does not retain any more of your personal information than we believe is necessary for any of the purposes set out in this Privacy Policy or which is dictated by legal or professional requirements. We will destroy, erase or make anonymous documents or other records containing Personal Information as soon as it is reasonable to assume that the original purpose of obtaining and storing it is no longer being served by retention of the Personal Information or retention is no longer necessary for legal, business or professional purposes. We will take reasonable care when destroying Personal Information so as to prevent unauthorized access.

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How is your personal data collected?

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We use direct methods to collect data from and about you including through:

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Direct interactions

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You may give us your identity and contact data by filling in forms or providing other information via our website.

 

This includes personal data for:

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• Donations;

• Volunteering or participating in our events;

• Seeking support or information; 

• Contracted for services;

• Providing us with feedback; or

• Subscribing to our publications.

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Automated technologies or interactions

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As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns.  We collect personal data by using cookies and other similar technologies.  We may also receive technical data about you if you visit other websites employing our cookies.  Please see our website for further details.

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The purpose of collecting your personal data:

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We may collect personal information for the following purposes:

1. To process and issue receipts for donations, if and when necessary;

2. To communicate with you regarding our activities, events, and campaigns;

3. To comply with legal obligations or requests from regulatory authorities;

4. To recognize and appreciate your support (e.g., donor acknowledgments);

5. Subscribe to our publications;

6. Health information (offering support or resources to individuals impacted by breast cancer);

7. Sending communications about upcoming events, fundraisers, and other charity activities;

8. Analyzing trends to improve services, events and fundraising efforts;

9. To provide information you request or respond to inquiries; or

10. Managing and coordinating volunteers and staff.

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We will only use personal information for the purposes stated or as permitted by law.

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Disclosure of Personal Information

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 Personal information may be disclosed to:

• Trusted service providers (e.g., payment processors, event organizers), subject to confidentiality agreements; 

• Partners or collaborators in events and programs, where necessary and with appropriate safeguards; 

• Regulatory and legal authorities as required by law; or

• Third party service providers who assist in service delivery (subject to confidentiality agreements).

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We will ensure any third-party services we work with have the appropriate privacy safeguards in place to protect personal information.

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Personal information will not be sold, rented, or shared for marketing purposes.

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Safeguarding of Personal Information

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We implement appropriate technical, physical, and administrative safeguards to protect personal information from unauthorized access, loss, or disclosure. This includes:

• Encryption and secure transmission methods for online donations and communications;

• Regular audits and security assessments of our systems;

• Access controls and user authentication; or

• Employee/volunteer training on privacy and security policies.

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Retention and Disposal

 

Personal information will be retained only for as long as necessary to fulfill the purposes for which it was collected and as required by applicable laws. When no longer required, information will be securely disposed of via shredding, secure deletion, or other approved methods.

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Access and Correction

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Individuals have the right to access their personal information and request corrections if it is inaccurate or incomplete. Requests can be submitted in writing to the Privacy Officer. A response will be provided within the timeframe required by law.

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Consent and Withdrawal

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The Charity obtains consent for the collection, use, and disclosure of personal information, except were permitted or required by law. Individuals may withdraw consent at any time, subject to legal or contractual obligations.

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Complaints and Inquiries

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Concerns regarding personal information handling should be directed at the Charity’s Privacy Officer. Complaints will be investigated promptly, and corrective action will be taken as necessary. If unresolved, individuals may contact the relevant privacy regulatory authority.

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Policy Review and Updates

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This policy is reviewed annually and updated as necessary to ensure compliance with legal requirements and best practices.

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Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

• Object to processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided with consent for us to use or where we used the information to perform a contract with you.

 

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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If you wish to exercise any of the rights set out above, please contact us at privacy@projectpink.bm.

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No fee is usually required

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You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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What we may need from you

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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Time limit to respond

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We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Acknowledgment

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By engaging with the Charity, including donating, volunteering, or participating in events, you acknowledge that you have read and understood this Personal Information Protection Policy.

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This policy ensures that the charity remains transparent and accountable while protecting the privacy of all individuals it serves.​