QFI Privacy Policy

Effective Date: October 1, 2020

Qatar Foundation International, LLC (“QFI”, “we” “us” or “our”) is a U.S.-based member of Qatar Foundation (QF). QFI works globally to support primary and secondary students and teachers as they explore new ways of enriching the classroom learning experience.  We focus on student-centered approaches that foster a deeper understanding of the Arab world through the teaching of Arabic, and about the region’s histories, cultures, and peoples.  We value your privacy. In this Privacy Policy (“Policy”) we describe how we process personal data that we obtain about visitors to our website www.qfi.org (the “Site”) and the services available through our Site (collectively, the “Programming”).  

Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Processing means any operation or set of operations performed with or without the aid of automated processes in connection with personal data such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Entity Responsible for the Processing and Contact Details
Information We Collect About You and Its Sources
Legal Basis of the Processing of Your Personal Data
How We Use Your Personal Data and on what Legal Basis
With Whom We Share Your Personal Data
Transfer of Your Personal Data to a Third Country
Duration of Storage of Your Personal Data
Your Rights
Cookies and Other Tracking Mechanisms
Third Party Analytics
Third Party Links
Security
Changes to this Privacy Policy

Entity Responsible for the Processing and Contact Details

The entity responsible for the processing of your personal data (the controller) is:

Qatar Foundation International, LLC
1225 New York Ave NW
Washington, DC 20005
+1 202.652.0147

VeraSafe has been appointed as Qatar Foundation International’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27- representative.

Alternatively, VeraSafe can be contacted at: 

VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

Information We Collect About You and Its Sources

We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.

Information We Collect Directly From You. Certain areas and features of our Site and Services, for example signing up to receive newsletters, requires registration. To register you must provide your email address. If you do not provide us with your email address, we may not be able to perform certain services such as keep you informed about our work and grant opportunities. We also may collect additional optional information from you, however, you are not required to provide us with this information. If you apply for a grant application, we will receive information you submit through Survey Monkey Apply. Note that Survey Monkey Apply’s use of your personal information in connection with your user account is governed by Survey Monkey Apply’s own privacy policy, not this one.

Information We Collect Automatically. We may automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site, as well as aggregate information regarding the countries from which users visit our Site. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. If you are located in Germany, and where required by any applicable law, we will obtain your consent before carrying out this type of processing. Please see the section “Cookies and Other Tracking Mechanisms” below for more information. 

Legal Basis for the Processing of Your Personal Data 

We process your personal data for various purposes in accordance with the following legal grounds:

You can find the specific purposes of the data processing in the context of this website in the next section.

The processing of your personal data must be based on one of the following legal bases:

  • You have given your consent (Art. 6 (1) subparagraph 1 a) GDPR);
  • Processing is necessary to perform a contract with you, or in order to take steps your request prior to entering into a contract (Art. 6 (1) b) GDPR);
  • Processing is necessary for compliance with a legal obligation under EU law or under a Member State law to which we are subject (Art. 6 (1) c) GDPR);
  • Processing is necessary to protect your vital interests or the vital interests of another person (Art. 6 (1) d) GDPR);
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority which has been vested in us (Art. 6 (1) e) GDPR);
  • Processing is necessary for the purposes of the legitimate interests pursued by the QFI or of a third party, except where these interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, particularly where this concerns a child (Art. 6 (1) f) GDPR).

To the extent that we, in exceptional cases, process special categories of personal data about you (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation), then one of the following legal bases must also apply:

  • You have given explicit consent (Art. 9 (2) a) GDPR);
  • Processing is necessary to protect your vital interests or those of another person where the relevant person is physically or legally incapable for giving consent (Art. 9 (2) c) GDPR);
  • Processing relates to personal data which you manifestly made public (Art. 9 (2) e) GDPR);
  • Processing is necessary for the establishment, exercise or defence of legal claims (Art. 9 (2) f) GDPR);
  • Processing is necessary for reasons of substantial public interest, on the basis of EU law or Member State law which shall be proportionate to the aim pursued, which shall respect the essence of the right to data protection and which shall provide for suitable and specific measures to safeguard your fundamental rights and interests (Art. 9 (2) g) GDPR).

You can find the additional details on the purpose of the data processing and the relevant legal basis in the information provided in next section.

How We Use Your Personal Data and on What Legal Basis

We process your personal data (email address if provided or cookie data as detailed below) on the following legal basis for the following purposes: 

Purpose Legal Basis Legitimate Interest for Balancing of Interests
Providing Our Programming. To provide our Programming to you, to communicate with you about your use of our Programming, and to respond to your inquiries. Performance of the contract or legitimate interest We have a legitimate interest in providing an internet presence (website), also to unregistered users, in an effort to provide general information about our company.
Research and Analytics. To better understand how users access and use our Site and Services, on an aggregated and in case of your prior informed consent also on an individualized basis, in order to improve our Site and Services and respond to user desires and preferences (“web analytics”). Legitimate interest (for aggregated research and analytics).

Consent (for individualised research and analytics).

We have a legitimate interest in receiving information about the use of the website including, in particular, for purposes of improving our offerings.
Security. Identification of disruptions and assurance of system security, including detection and tracking of unauthorized access attempts and access to our web servers. Satisfaction of our legal obligations with respect to data security and Legitimate interest We have a legitimate interest in eliminating disruptions, ensuring system security, and detecting and tracking unauthorized access attempts.
Marketing and Communications. For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, or to otherwise contact you about programs and opportunities we think may interest you. We also may use the information that we learn about you to assist us in promoting our Programming on third party websites on an aggregated level. Legitimate interest regarding marketing communication via mail.

Where you are located in Germany, or where we are otherwise required by law to obtain your consent, we will rely upon such consent for sending you marketing communications via e-mail or telephone. 

We have a legitimate interest in contacting you for marketing and promotional purposes. 
Protecting and defending Rights and Interests. To protect the safety, rights, property, or security of QFI, the Programming, any third party, or the general public; to detect, prevent, or otherwise address fraud, to prevent or stop activity that QFI, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; to conduct audits; and to enforce this Privacy Policy and our Terms & Conditions Legitimate interest We have a legitimate interest in asserting, protecting and defending our rights.
Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. Satisfaction of our legal obligations

 

With Whom We Share Your Personal Data

We share your personal data with the following recipients:

Processors:

  • Service Providers. We may disclose the information we collect from you with third parties who help manage our business and deliver services. These include IT service providers who help manage our IT and back office systems and marketing agencies who help us communicate with you about products or services.

Controllers:

  • Affiliates. We may disclose the information we collect from you to other parts of the Qatar Foundation in order to report on the use of QFI funding and impact of our work; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
  • Programming partners. We may disclose certain information we collect with our partners on joint programs, such as universities with whom we run programs.
  • Professional advisors: where necessary, we may disclose your personal data to our advisors, such as our lawyers and auditors.
  • Business Transfers. If we are restructured or merged with the Qatar Foundation or another foundation, if substantially all of our assets are transferred to another foundation, or as part of a bankruptcy proceeding, we may transfer the personal data we have collected from you to the other foundation.

In addition, we may, to the extent permitted by law, share personal data in order to comply with a legal obligation to which we are subject, for example, with national, legal or regulatory authorities in the framework of imminent or pending legal proceedings or a statutory audit, or in connection with legal proceedings or prospective legal proceedings, including in order to establish, exercise or defend our legal rights.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where parties qualify as data processors, we do not allow such third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfer of Your Personal Data to a Third Country

Your personal data may be transferred to third countries (i.e., countries that are not members of the European Economic Area), such as the USA where Qatar Foundation International, LLC is located, for the purposes set out above.  Some of these countries, including the USA, have more lenient data protection laws than those of the EU and therefore do not offer the same level of data protection required in the EU.

We will always ensure that appropriate or suitable safeguards are in place to protect your personal data, and that the transfer of your personal data is in compliance with applicable data protection laws. The data transfer only takes place on the basis of an adequacy decision of the Commission or on the basis of standard contractual clauses of the EU Commission (EU Model Clauses) or binding internal data protection regulations. 

If you are located in the EU, we will obtain your consent before making a transfer unless we can rely on another safeguard under applicable data protection law, such as the fact that the transfer is necessary for the performance of a contract with you or the implementation of pre-contractual measures taken by us on your request.  Any request for your consent will include informing you of the possible risks of such transfers due to the absence of an adequacy decision and appropriate safeguards prior to requesting your consent. You can obtain a copy of the relevant safeguard (where this consists of documented provisions) by contacting us using the information in the contact section above, noting that some details may be redacted for confidentiality reasons. 

Duration of Storage of Your Personal Data 

QFI endeavours to ensure that personal data is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. 

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. This usually means that we retain your data for the period of your relationship with us plus the length of any applicable statutory limitation period following the end of such relationship, although some data may need to be kept for longer. For example, in some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting  requirements, or, in specific circumstances to enable us to establish, exercise and defend legal rights and claims, and for other legitimate business reasons.

Your Rights

Where you are located within the European Union, as the data subject, you are entitled to the following data protection rights in respect of your personal data that is held by QFI:

Access:  You have the right to request access to your personal data, to receive information about the scope of data processing and data transfer performed by QFI, and to obtain a copy of your stored personal data.  

You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.

Rectification: You have the right to demand the immediate rectification of incorrect personal data and you have the right to have incomplete personal data completed. As noted above, you may modify personal information that you have submitted by logging into your account and updating your profile information. 
Erasure: You have the right to demand the immediate deletion or erasure of your personal data stored by QFI, where certain legal requirements are satisfied.

This is the case, in particular, if:

  • your personal data is no longer needed for the purposes for which it was collected;
  • the sole legal basis for processing such data was your consent, and you have withdrawn such consent;
  • you have objected to processing on the legal grounds relating to your particular situation, and we cannot prove that there are overriding legitimate grounds for processing;
  • your personal data were processed unlawfully; or
  • your personal data must be erased in order to comply with legal requirements.

If we have transmitted your data to third parties, we will inform them about the erasure to the extent required by law.

Please note that your right to erasure is subject to certain limitations. For example, we may not and/or must not erase data that we are still required to retain due to statutory retention obligations. In addition, your right of erasure does not extend to data that we need in order to assert, exercise or defend against legal claims, unless other grounds for continued storage exist.

Restriction of Processing: Under certain conditions, you have the right to request that processing be limited (i.e., the marking of stored personal data with the aim of limiting its processing in the future). The requirements are:  

  • The accuracy of your personal data is contested by you and QFI must verify the accuracy of the personal data;
  • the processing is unlawful, but you oppose the erasure of the personal data and request the restriction of their use instead; 
  • QFI no longer needs the personal data for the purposes of processing, but you require the data to establish, exercise or defend your legal claims.
  • you have objected to processing pending the verification of whether the legitimate grounds of QFI override your legitimate grounds.

Where processing has been restricted, such data will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest the EU or an EU Member State.

Data Portability:  To the extent that we automatically process your personal data that you have provided to us based on your consent or any contract with you, you have the right to receive such data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from QFI. You also have the right to have the personal data transmitted directly from QFI to another controller where technically feasible, provided that such transmission does not adversely affect the rights and freedoms of others.
Right to Object: If we process your personal data on grounds of legitimate interests or in the public interest, then you have the right to object to the processing of your personal data on grounds relating to your particular situation. In addition, you have an unrestricted right to object if we process your data for our direct marketing purposes. Please see our separate note in the section titled “Information about your right to object”.

In certain situations, in the context of a balancing of interests, we will grant you an additional unrestricted right to object.

Withdrawal of Consent: If you have given consent to the processing of your personal data, then you can withdraw such consent at any time. Please note that the withdrawal applies prospectively only. Processing that occurred before the withdrawal of consent is unaffected. Where you have withdrawn consent but we retain the personal data, we will only continue to process that personal data where necessary for those purposes where we have a different legal basis to do so.  However, this may mean that we cannot continue to provide you with all or some of our services, in which case we may terminate the relevant service(s).  
Complaint:  Furthermore, you have a right to file a complaint with a data protection authority, if you believe that the processing of your personal data is unlawful. The right to file a complaint is without prejudice to any other administrative or judicial remedies. 

 

Information about Your Right to Object

Right to object for personal reasons

You have the right to object to the processing of your personal data on grounds relating to your particular situation. The prerequisite for this is that the data processing takes place in the public interest or on the basis of a balancing of interests. This applies also to profiling.

Insofar as we base the processing of your personal data on a balancing of interests, we generally assume that we can demonstrate compelling legitimate grounds but will, of course, examine each individual case.

In the event of an objection, we will no longer process your personal data, unless 

  • we can demonstrate compelling legitimate grounds for the processing of these data that override your interests, rights and freedoms, or
  • your personal data serves the establishment, exercise or defence of legal claims.

Cookies and Other Tracking Mechanisms

We and our third party service providers may use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). If you are located in Germany, and where required by applicable law, we will obtain your consent before carrying out this type of processing. 

Cookies.  Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

 

You can find a list of the cookies in use below:

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Third Party Analytics

This website uses Google Analytics, a web analysis services offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics uses cookies. The information on your use of the website collected by the cookie is usually stored on the server in Ireland and may be transferred to a Google server in the USA, where it is saved. As an IP anonymity function is activated on this website, Google will shorten your IP address in member states of the European Union or other contracting states of the agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. 

Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising. Specific cookie expirations are listed in the table above.

Google will use the information generated using the cookie on our behalf to evaluate your use of the website, compile reports on website activities, and provide us with other services associated with the website and Internet use. The IP address transmitted by your browser to Google Analytics will not be linked to other Google data. 

You can set your browser software to prevent cookies from being saved. Please note, however, that if you do so, you might not be able to use all of the functions offered by this website. You can also prevent Google from storing the data generated by the cookie relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in that is available here [https://tools.google.com/dlpage/gaoptout].

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

Third-Party Links

Our Site and Services may contain links to third-party websites such as Facebook, Instagram, YouTube, Flickr, and Twitter. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security 

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Changes to this Privacy Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, at https://www.qfi.org/privacy-policy/. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

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