THE NETHERLAND-AMERICA FOUNDATION (NAF) PRIVACY POLICY

Last updated: June 8, 2021

Scope of the Privacy Policy

The Netherland-America Foundation (the “NAF”) respects your privacy and knows that you care about how we use and share your information. This privacy policy describes how the NAF collects, shares, uses and protects personal information. By using this website, https://thenaf.org (“we”, “us”, “our”), you are accepting and consenting to the practices described in this Privacy Policy.

Our Privacy Policy Covers:

• Personal information we collect and why we collect it.
• Cookies and other technologies.
• How we use your personal information.
• How we share your personal information.
• How we protect your personal information.
• How long we keep your personal information.
• Your rights and choices.
• Data transfers.
• Changes to this privacy policy.
• Questions, Concerns or Complaints.

Personal Information We Collect and Why We Collect

Information you give us. The information about you that you provide to us by filling in forms on our site, https://thenaf.org, participating at events organized or attended by the NAF, corresponding with us by phone, electronic mail or visiting our offices. It includes information that you provide when you complete grant applications, student loan applications, contact us forms, donation forms, sign up for newsletter through our third-party, engage in social media functions on our site or other activities commonly carried out on the site, as well as when you request support within our site.

Personal information, also known as personally identifiable information (PII) or personal data, for purposes of this Privacy Policy, means any information that (i) directly and clearly identifies an individual or identifiable natural person, or (ii) can be used in combination with other information to identify an individual or identifiable natural person. Personal information does not include such information if it is anonymized or de-identified by making it impossible or impractical to connect personal data to an identifiable person.

The information you provide may include basic personal information such as your name, address, e-mail address, phone number, student field of study, university and payment method. The NAF may collect more sensitive information from you such as financial and credit card information, demographic information, and other government identification numbers where it is appropriate or necessary for conducting business.

Information we collect about you. With regard to each of your visits to our site, we may automatically collect information such as:

• Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, source domain names, your login information, browser type and version, time zone setting, length of time spent on our site and operating system and platform.
• Information about your visit even if you have not created an account or logged in, including the full Uniform Resource Locators (URL), specific web pages, clickstream to, through and from our site including date and time, pages you viewed or searched for, page response times, download errors, length of visits to certain pages and any phone number used to call our customer service number.

The NAF may also supplement the personal information we collect from you with information we receive from third parties, including our business partners, analytics and other service providers. We process personal information for lawful reasons as well as to help us improve the overall accuracy of the information and its completeness, and to better tailor our interactions with you.

The information we collect assist in enhancing the security of our information systems and assessing the effectiveness of our programs, communication methods with our donors, and tracking popularity of payment methods. The collected information is also used to aggregate statistical data, facilitate system administration and improve our site.

Cookies and Other Technologies

We use cookies and similar tracking technologies to help us better understand your experience with our site and track the activity on our site. We collect information such as your IP address, operating system, date and time to measure performance and improve our site. Further, cookies help us to provide you with a good experience when you browse our site.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Cookies are a technology that can be used to help personalize your use of our site. For example, a cookie may allow us to recognize your browser, whereas another cookie may store your preferences.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, it is possible that some portions of our site will not work properly.

Examples of Cookies we use:

• Necessary Cookies. We use necessary cookies to enable core functionality such as security, network management, and accessibility.
• Session Cookies. We use Session Cookies to operate our site.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

Third Party Cookies. The use of cookies by third parties is not covered by our Privacy Policy. We do not have access or control over these cookies. Third parties use session ID cookies to make it easier for you to navigate our site. We use third-party services to provide the necessary hardware, software, networking, storage, and related technology required to run and improve our services.

Web Beacons. Our third party partners may employ web beacons to track online user movement to help us better understand what content is effective. Web beacons are tiny graphics with a unique identifier that are embedded in websites and in newsletter emails. With web beacons, our third party partners may collect information about you, such as your IP address, your browser or email client type, and other similar details. We use the data from our third party partners to improve our services.

How We Use Your Personal Information

Legal Basis for Processing Personal Information. Personal information can only be processed under the European Union’s General Data Protection Regulation (GDPR) if there is at least one lawful basis to do so. We process the information we collect, both on its own and combined with any other information we collect about you as discussed above, for the following purposes:

• To confirm details of your donations and payment transactions and other records of your involvement with us;
• To notify you about updates to our special programs, upcoming events and new services;
• To target current or prospective donors (subject to your consent where required by applicable law);
• To assist us in offering you a personalized experience or otherwise tailor our services to you (for example, in order to provide you with specific information applicable to your student grant or loan application);
• To provide you with requested information, services or technical support;
• To provide you with useful content and ensure the proper functioning of our services;
• To offer and improve our services;
• To facilitate your movement through our websites or your use of our services;
• To do a better job of advertising our services or events (subject to your consent where required by applicable law);
• To diagnose problems with our servers or our services;
• To analyze traffic patterns and administer our websites;
• To track popularity of payment sources and forms; and
• As otherwise described in this privacy policy.

Payment information that you provide to us, including credit card data, will only be used to process payment for the services.

How We Share Your Personal Information

Sharing of Personal Information. We may share your personal information with:

• Our donors and grantors, including our Friends Fund partners and Universities, but only to the limited extent required by such individuals and organizations for the purpose of evaluating specific grant proposals or fundraising requests and for no other purposes;
• Third party service providers and vendors, as more fully described below; and
• Legal or regulatory authorities and other relevant third parties for legal reasons.

Sharing With Service Providers and Vendors. Occasionally, the NAF enters into contracts with carefully selected service providers to assist us in servicing you or to assist us in our advertising activities. The categories of service providers we share your personal information with include:

• Fulfillment companies such as mailing and event coordinators and organizers
• Web hosting and archiving services;
• Cloud hosting services;
• Analytics services;
• Advertising networks;
• Customer relationship management services;
• Customer support services;
• Software services;
• Professional services;
• Storage services;
• Search engine optimization services; and
• Information technology services.

The NAF does not sell personal information, as the terms “sell” and “sale” are understood under applicable law.

Legal Process. If legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, public authorities (including to meet national security or law enforcement requirements), and other relevant third parties, such as internet service providers, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, to bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be:

• Violating our terms and conditions of use located here: https://thenaf.org/terms;
• Causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or
• Violating federal, state, local, or other applicable law.

How We Protect Your Personal Information.

Security. The transmission of information via the internet, email or text message is not completely secure. While we will do our best to protect the privacy of your personal information, we cannot guarantee the security of your information transmitted through the services or using an email. Any transmission is at your own risk. Once we have received your information, we will take appropriate physical, technical and administrative measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as Secure Sockets Layer (SSL) and Transport Layer Security (TLS) protocol.

How long We Keep Your Personal Information

We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Your personal data is stored by the NAF on its servers located in the United States. We retain data for the duration of the student’s, donors or member’s relationship with us and for a period of time thereafter to allow members to recover accounts if they decide to renew, to analyze the data for NAF’s own operations, and for historical and archiving purposes associated with NAF’s history as a foundation.

For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at info@thenaf.org.

Your Rights and Choices

Data Subject Rights

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. The individual rights where the GDPR or related data protection laws apply may include:

• Right to be Informed. Inquire whether we collect and process personal information about you
• Right of Access. Access data we hold about you and certain information about how we use it and who we share it with.
• Right to Rectification. Ask us to update or correct your personal information if it is incomplete.
• Right to Erasure. Request that we delete the personal information we hold about you in certain limited circumstances.
• Right to Restrict Processing. Request that we stop processing the personal information we hold about you.
• Right to Data Portability. Request that your personal data be provided to you or another organization in a structured, commonly used and machine-readable format, in certain limited circumstances.
• Right to Object. Oppose to our processing of data about you, including in relation to processing your personal data for advertising or promoting programs and events purposes.

We do not use automated decision making in processing your personal information for services.

To exercise any of the above rights, please contact us by email at info@thenaf.org or call us at 212.825.1221. You may also write to us:

505 8th Avenue, Suite 12A-05
New York, NY 10018, U.S.A.

Choice/Opt-Out

Email

You always have the opportunity to opt out of our communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at info@thenaf.org. Some communications from us are considered transactional or service communications (for example, important account notifications and billing information). You agree to receive these transactional and service communications as a condition of the services that we provide to you. You must cancel your accounts for all services if you do not wish to receive any transactional or service communications from us. To cancel your account, please contact us at Support. You may still receive newsletter communications from us even after you cancel your account unless you also opt-out of our newsletter communications, as described above.

Phone

If you do not want to receive calls by phone, you may contact customer support and indicate your preference to us.

Information from Third Parties

To manage the information we receive about you from a social networking site or other third party, you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy policy and the information the third party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our services.

Consent

You have the right to withdraw your consent to process your personal information at any time in circumstances where we are relying on your consent as our basis for processing. To exercise any of your rights, please send an email to info@thenaf.org or call us at 212.825.1221. We will require you to verify your identity before responding to any requests to exercise your rights.

Minors

Our services are not directed to persons under age 16. We do not knowingly collect personal information from minors under 16. If you are a parent or guardian of such a child and become aware that your child has provided personal information to us, please contact us as described in this privacy policy and we will take reasonable steps immediately to remove any such information.

Transferring Personal Information to the U.S.

The NAF has its headquarters in the United States. Information we collect about you will be processed in the United States. By using our services, you acknowledge that your personal information will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Pursuant to Article 46 of the GDPR, the NAF is providing appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EU and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when new draft model clauses are approved.

Depending on the circumstance, the NAF also collects and transfers to the U.S. personal information with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of the NAF in a manner that does not outweigh your rights and freedoms. The NAF strives to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with the NAF and the practices described in this Privacy Policy. The NAF also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate.

For more information or if you have any questions, please contact us at info@thenaf.org.

Changes to this Privacy Policy

The NAF reserves the right to modify this privacy policy at any time, so please review it frequently. If we decide to change this privacy policy in any material way, we will notify you here, by email, or by means of a policy on our website. In all cases, your continued use of any services constitutes acceptance to any such changes.

Questions, Concerns or Complaints

If you have any questions about this privacy policy or our data handling practices, or you wish to make a complaint, please contact us at info@thenaf.org or by regular mail at:

505 8th Avenue, Suite 12A-05
New York, NY 10018, U.S.A.
212.825.1221