Protection of Information and Storage

SpareTime Global needs to caution you that the Sponsor A Child website could be vulnerable to hacking, virus attacks, and your personal data may be at risk. SpareTime Global Limited takes all the necessary and reasonable caution to protect the Sponsor A Child service and data.

• Your personal data will be processed lawfully and in a transparent manner so that you are aware of all processing activities connected with your personal data.
• Your personal data will be collected by us only for a limited number of purposes (ex- validation, processing, and authorization) and not further processed in a manner that is incompatible with those purposes while not collecting personal data than is required.
• Your personal data will be accurate and, where necessary, kept up to date.
• Your personal data will be kept in a form that permits identification for no longer than is necessary for the purposes for which that personal data is processed.
• Your personal data will be processed in a manner that ensures appropriate security of the personal data.

If you provide us with the personal data of another individual, you hereby represent that you have obtained consent from that individual prior to providing their personal data to us.

If you are under the age of 18, you will not be able to avail of the services of the platform.

For Data Collectors: If you are providing personal data of individuals under the age of 18, we take it that you have obtained the consent of the respective parent, guardian, or person who has parental responsibility over the individual under the age of 18 before sending us such personal data (for example, name, address, gender, date of birth, school name, grade, and email address, etc.).

What Personal Data Do We Collect?

1. Children
• Full Name
• Date of Birth
• Gender
• Permanent Address
• District
• School Name & Class
• Father’s Name
• Mother’s Name
• Family Income
• Special Talents
• Image (Passport Size)
• Health and Nutrition Information
• Education-related information
• Extra-curricular activity-related information
2. Guardians
• Full Name
• Permanent Address
• National Identity Card No
• Relationship to the Child
• Current Job
• Phone Number
• Bank Account Number
• Bank Name
• Bank Branch
• Letter (Stating why mother or father is not the guardian)
3. Donors
• Contact Information (name, address, email address, and telephone number)
• Financial Information (financial statements)
• Fund Transfer Slip
• Profile Image
4. Teachers
• Contact Information (name, address, school name, email address, and telephone number)

The operators of the platform may collect other additional personal data through the platform as part of the service, including but not limited to, supporting documents and personal data relating to the specific cause.

Purposes of Using Your Personal Data

1. Children
• Providing sponsorship to eradicate hardships faced;
• Notifying about changes to the systems, procedures, and features of the Sponsor A Child program;
• Verifying your identity when required;
• Undertaking satisfaction surveys based on your use of Sponsor A Child services for service enhancements and improvements;
• Compliance with laws and legal, contractual, and/or regulatory obligations and protecting or exercising our legal, contractual, and/or regulatory rights and remedies;
• Other legitimate purposes.
2. Guardians
• Providing sponsorship to eradicate hardships faced;
• Notifying about changes to the systems, procedures, and features of the Sponsor A Child program;
• Sending notifications concerning fund receipts and sponsorship recipient status;
• Sending information through telephone calls, text messages, or other digital channels, emails, etc. about the Sponsor A Child program;
• Verifying your identity when required;
• Responding to complaints or inquiries;
• Undertaking satisfaction surveys based on your use of Sponsor A Child services for service enhancements and improvements;
• Compliance with laws and legal, contractual, and/or regulatory obligations and protecting or exercising our legal, contractual, and/or regulatory rights and remedies;
• Other legitimate purposes.
3. Donors
• Providing sponsorship to eradicate hardships faced;
• Notifying about changes to the systems, procedures, and features of the Sponsor A Child program;
• Sending notifications concerning fund transfers, fund receipts (by sponsored child’s family), and progress report availability status;
• Sending information through telephone calls, text messages, or other digital channels, emails, etc. about the Sponsor A Child program;
• Verifying your identity when required;
• Responding to complaints or inquiries;
• Undertaking satisfaction surveys based on your use of Sponsor A Child services for service enhancements and improvements;
• Compliance with laws and legal, contractual, and/or regulatory obligations and protecting or exercising our legal, contractual, and/or regulatory rights and remedies;
• Other legitimate purposes.
4. Teachers
• Providing required facilities and services to carry out teacher-related tasks;
• Notifying about changes to the systems, procedures, and features of the Sponsor A Child program;
• Sending notifications concerning fund receipts (by sponsored child’s family), and progress report uploading status;
• Sending information through telephone calls, text messages, or other digital channels, emails, etc. about the Sponsor A Child program;
• Verifying your identity when required;
• Responding to complaints or inquiries;
• Undertaking satisfaction surveys based on your use of Sponsor A Child services for service enhancements and improvements;
• Compliance with laws and legal, contractual, and/or regulatory obligations and protecting or exercising our legal, contractual, and/or regulatory rights and remedies;
• Other legitimate purposes.

We use reasonable efforts in accordance with industry best practices to ensure that the above- mentioned maintain the confidentiality and integrity of your personal data and are restricted from using your personal data for any unauthorized purposes.

Transfer of Personal Data

We may transfer your personal data across different systems (ex-servers) to assist you well. Where your personal data has been transferred to systems (especially outside of Sri Lanka), the transfer of your personal data is carried out under organizational, contractual, and legal measures and with reasonably adequate levels of protection implemented as well as any additional local legal requirements receiving this data in order to safeguard your personal data.

Storing and Protecting Personal Data

We may collect and store your personal data in electronic or physical form, depending on the requirement. Such personal data may be stored at our and third-party premises within IT Systems (e.g. external cloud storage, internal or third-party management systems, e-mails, databases, hard drives etc.), and physical warehouses etc.

We endeavor, where practicable, to process your personal data in a safe environment by preventing any unauthorized or unlawful processing of personal data or accidental disclosure, loss, or destruction of, or damage to, such personal data. We have implemented various physical, technical, and administrative security measures to protect your personal data and our network from unauthorized access. Some of these measures include:

• encryption of personal data;
• strict adherence to privacy and security practices;
• periodic security assessment and reviews to upgrade our practices;
• restriction of access to such personal data to personnel who have a need to know such personal data.

Retention of Personal Data

We will retain your personal data only for as long as such data is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws or a legitimate business requirement. In all cases, such personal data may be held for a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for legal or regulatory purposes). Once personal data surpasses its retention period and if there is no valid reason to retain such personal data, the personal data will be securely disposed of.

Consequences of Not Providing Personal Data

We may require the collection of certain personal data about you and failure to provide such information may:

• Result in us being unable to process your request and/or provide you with our service.
• Result in us being unable to respond to your requests on our service.
• Limit or prevent access to certain features on our website, web links or digital platforms.
• Result in us being unable to update you on the latest updates regarding our services.
• Result in your inability to receive invitations to charity campaigns.
• Negatively affect our ability to communicate with you.
• Be in violation of any applicable law or regulation that requires us to collect such personal data.

Cookies

SpareTime Global Limited may place a text file called a “cookie” in the browser files of your electronic device. The cookie itself does not contain personal information although it will enable the Sponsor A Child website to relate your use of the Sponsor A Child services to information that you have specifically and knowingly provided to the Sponsor A Child website.

The Cookies enable SpareTime Global Limited to remember your choices and some data field contents which you would be required to fill in.

Advertisements

On the Sponsor A Child website, SpareTime Global Limited will not post advertisements provided by advertisers. In that case, the electronic device ID will not be transmitted to third parties, hence your risk and volition are protected. By not allowing such advertisements, SpareTime Global Limited does recommend or market or warranty the website’s quality, commitment, deliverables, genuineness, and commitment to protecting your personal information.

Pre-approved sharing of personal information

SpareTime Global Limited endeavors to protect your personal information. SpareTime Global will not share your personal information with its donors, teachers, beneficiaries, and its business partners. Personal information could not be shared so you may not receive newsletters, offers, information about new products, services, launches, facilities, schemes, and other information, if applicable. The information collected from you and other users may be analyzed in different manners. SpareTime Global will not share such analysis with any of its stakeholders.

In case SpareTime Global Limited is required to disclose your personal information in order to assist the government authority or in adherence to the court or to protect the interest of SpareTime Global Limited and/or any particular user(s), SpareTime Global will disclose it by obtaining prior permission from you.

Links to the other websites

This privacy policy applies only to the services provided by Sponsor A Child Program. The services may contain links to other SpareTime-related websites operated or controlled by SpareTime Global Limited. The policies and procedures we described here may differ on those sites. We strongly advise you to review the privacy policies of every such website. The links from the services do imply that SpareTime Global Limited endorses or has reviewed the SpareTime Global sites. We suggest contacting those sites directly for information on their privacy policies.

Changes to the privacy policy

SpareTime Global Limited has and continues to have the right to modify, change or update the privacy policy at any time. However, SpareTime Global Limited will use your personal information in a manner consistent with the privacy policy at the time you shared personal information. You are encouraged to check the Sponsor A Child website often to get updated about the privacy policy. You acknowledge that by virtue of usage of the Sponsor A Child website you provide acceptance of the privacy policy. All questions are to be addressed to sponsorachild@sparetime.global.

If you have any questions about this privacy policy, the practices of this site, or your dealings with this site, please contact us at:

SpareTime Global Limited
425/3 1/1 Thimbirigasyaya Road,
Colombo 05,
Sri Lanka.
sponsorachild@sparetime.global