Felicitas Publica Limited is committed to protecting the privacy of visitors to our website and users of our app Felicitas, as well as our employees.
In this policy, "Felicitas" refers to Felicitas staff, board members, cooperating attorneys, interns, employees, and consultants, all of whom are bound by law or contract to keep confidential information they receive as part of their assistance to Felicitas.
Felicitas does not sell or rent website visitor or user information under any circumstances, and we do not share user or visitor information without prior consent except as compelled by law.
Information Gathered by Felicitas
Logging: For visitors to our website and users of our application we generally log requests to our website and do internal analytical logging (also described further below) for up to seven days from when the data was collected.
Circumstances in which Felicitas may need to log and retain technical information for longer than seven days include when we believe it is reasonably necessary for Felicitas' mission and functionality, including situations such as:
- site testing,
- diagnosis of technical problems,
- defending against attacks to the site,
- handling a spike in traffic or other abnormal, short-term circumstances, or
- Cookies: We do not use persistent ID cookies on this site.
Voluntarily Submitted Information: In addition, Felicitas collects and retains information you voluntarily submit to us. It is up to you whether to submit information to us, and how much information to provide. If you choose to become a Felicitas user, we may ask for identifying information such as your name, email address, mailing address and phone number and will retain that information.
We may ask for additional personal information when you provide feedback or comments, or otherwise communicate with us.
Use of Information
If you provide information for publication we may use your name and contact information you have provided to us to provide you with attribution.
Third-Party Service Providers to Felicitas
Portions of the Felicitas site, including some of our individual action alert webpages, are operated by third-parties.
Where possible, we take steps to limit the ability of third parties to retain data about our users. These service providers may place session cookies on your computer.
Felicitas' service providers may also log standard technical information, such as the numerical Internet Protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our site; and the Internet address of the website from which you linked directly to our site. Our service providers may also store and organize the personal information collected through this site on our behalf.
Felicitas' third party providers primarily process information in the United States, but may process data in other jurisdictions. Where applicable, we have entered into General Data Protection Regulation (GDPR) compliant Data Protection Addendums with third-parties who process data on our behalf.
In addition, for all of Felicitas' service providers, hosting providers and credit card processors and any other providers we may use in the future, the information collected from Felicitas users remains protected by the terms of our agreements with those providers and we will ensure that the information to be kept confidential and disclosed only to employees who require such access in the course of their assigned duties. Felicitas also requires all of our third-party service providers to notify Felicitas if they receive legal process seeking information about visitors to Felicitas' website.
Felicitas may change the specific third-party providers from time to time, and will transfer stored information to any new provider subject to similar restrictions and agreements. From time to time, Felicitas may work with third-party consultants or other service providers who may have access to personally identifiable information. In such cases, we will restrict their use of personally identifiable information in accordance with their assigned tasks.
Third-Party Services and APIs
Felicitas' site also provides links to or interacts with a wide variety of third-party websites, including interactive links to sites like social media, telephone calling services, mapping services, or video hosting websites, often via application programming interfaces (APIs). Felicitas is not responsible for, and does not have any control over, the privacy practices or the content of such third parties.
We encourage users to read the privacy policies of any website visited via links from or interactions with the Felicitas website. Where appropriate, we will provide specific notice of these third-party services at the point of interaction. It is our policy not to include third-party resources when users initially load our web pages, but we may dynamically include them later after giving the user a chance to choose to interact with them. If you believe a third-party resource is automatically loading, please let us know so we can address it.
Disclosure of Your Information
While Felicitas endeavors to provide the highest level of protection for your information, we may disclose personally identifiable information about you to third parties in limited circumstances, including: (1) with your consent; or (2) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other judicial or administrative order.
If we are required by law to disclose the information that you have submitted, we will attempt to provide you with prior notice (unless we are prohibited or it would be futile) that a request for your information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address, or by postal mail if you have entered a postal address. If you do not challenge the disclosure request, we may be legally required to turn over your information.
In addition, we will independently object to requests for access to information about users of our site that we believe to be improper and we have done so.
Updating or Removing Your InformationYou may choose to correct, update, access, or delete the user information you have submitted to us by sending an email requesting changes to email@example.com.
Your consent to our use of your information is very important to us. If you would like to withdraw your consent to receive our newsletter, alerts and other bulk emails, you may use this subscription management page to unsubscribe. If you would like to otherwise withdraw your consent, restrict or object to Felicitas' processing of your data, please email firstname.lastname@example.org.
Data Storage and RetentionFelicitas' server logs are stored and retained as explained above in the section on logging.
If you communicate with Felicitas, such as through email@example.com, we keep records of those communications indefinitely, pursuant to our document retention policy (described below).
Financial records of donations and other transactions are retained indefinitely, pursuant to our document retention policy. Paper records of donations, such as event donation forms and signup sheets, are typically destroyed soon after entry. Check copies and payment distribution details are normally kept up to seven years. Accompanying donor information is kept indefinitely unless the individual requests that it be removed.
Our document retention policy provides that Felicitas generally retains documents for the period of their immediate or current use, unless longer retention is necessary to comply with contractual or legal requirements. However, data storage periods are based on Felicitas' assessment of its needs and might include retaining some documents for historical reference and retaining some documents because Felicitas has insufficient organizational resources available to dedicate to their review and destruction, and/or other pertinent factors.
If we inadvertently collect more personal information than intended, we endeavor to delete the extraneous information. When we no longer need to retain information or when deleting information on request, we endeavor to remove all copies. However, please understand that deleted information may continue to persist on backup media.
Felicitas employs industry standard security measures to protect the loss, misuse, and alteration of the information under our control, including appropriate technical and organizational measures to ensure a level of security appropriate to the risk, such as the pseudonymization and encryption of personal data, data backup systems, and engaging security professionals to evaluate our systems effectiveness. Felicitas has turned on HTTPS by default.
Although we make good faith efforts to store information collected by Felicitas in a secure operating environment, we cannot guarantee complete security.
If you have any questions about our privacy and data protection practices, you can reach Felicitas at:
Felicitas Publica Limited
73 Baker St
W1U 6RD London, UK
If our processing of your personal data is covered by EU law, you may also lodge a complaint with the relevant data protection supervisory authority for your country of residence.