Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, individual customers and customer personnel.

1.2 This policy applies where we, acting as data controller in respect of the personal data of such persons, determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website.

1.4 In this policy, "we" and "our" refer to Centro Ann Sullivan del Perú (CASP). For more information about us, see Section 14.

2. The personal data that we collect

2.1 In this Section 2, we have set out the general categories of personal data that we process.

2.2 We may process data that allows us to contact you ("contact data"). Contact details may include your name and email address. The source of the contact data is you and/or your employer via our contact forms or email newsletter forms.

2.3 We may process information contained in or relating to any communication you send to us or from us ("communication data"). Communication data may include the content of the communication and metadata associated with the communication. Our website will generate the metadata associated with the communications made through the contact forms of the website.

2.4 We may process data about your use of our website and services ("usage data"). Usage Data may include your IP address, geographic location, browser type and version, operating system, referral source, length of visit, pages viewed, and website navigation paths, as well as information about time, frequency, and the pattern of your use. The source of the usage data is our analytics tracking system.

3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations - We may process your personal data for the purposes of operating our website and business. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.3 Relationships and communications - We may process contact data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, individual customers, and customer personnel, the maintenance of relationships, and the proper administration of our website and business.

3.4 Research and analysis - We may process usage data for the purposes of researching and analyzing the use of our website, as well as researching and analyzing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving, and securing our website and business generally.

3.5 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases, and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.6 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website and business, and the protection of others.

3.7 Legal claims - We may process your personal data where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

3.8 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Disclosing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies. This means our subsidiaries, our ultimate holding company, and all its subsidiaries insofar as reasonably necessary for the purposes and on the legal bases set out in this policy.

4.2 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for providing our services according to our contracts.

4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.4. We will not license or publish any of your personal data. We do not and will not sell any personal data to third parties for their own commercial use.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data, if you reside in the European Union, may be transferred to countries outside the European Economic Area (EEA).

5.2 Our website is hosted by Squarespace with servers in many different countries. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes will not be retained for longer than is necessary for that purpose or purposes.

6.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

7. Your GDPR rights

7.1 In this Section 7, we have listed the rights that people who reside in the European Union have under the General Data Protection Regulation (GDPR) data protection law.

7.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organization or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting: https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies may not contain any information that personally identifies a user.

9. Cookies that we use

10.1 Our website uses Google Analytics, Squarespace Analytics, and Pipedrive cookies to measure website usage, including the number of visitors, which pages are viewed, and how often they are viewed. The information collected by us will include IP address, pages visited, browser type, and operating system. The data will not and cannot be used to personally identify any user.

10. Managing cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11. Do Not Track Disclosure

11.1 Do Not Track (DNT) is a privacy preference that users can set in their web browsers. When a user turns on the DNT signal, the browser sends a message to websites asking them not to track the user. We do not respond to DNT. Consumers who use DNT mechanisms on this website are not treated differently than consumers who do not use DNT. You can learn more about DNT by visiting: https://allaboutdnt.com/

12. Children’s Online Privacy Protection

12.1 This site is not designed for or targeted at minors under the age of 18, and we request that minors not use this site. We do not knowingly collect data from anyone under the age of 13. If we become aware that we have received data from a person under the age of 13, we will take reasonable steps to delete such data from our records.

13. Amendments

13.1 We may update this policy from time to time by publishing a new version on our website.

13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

14. Our details

14.1 This website is owned and operated by Centro Ann Sullivan del Perú (CASP).

14.2 We are registered in Peru, and our registered office is located at Calle Petronila Álvarez 180, San Miguel, Lima, Peru

14.3 You can contact us:

(a) by mail to the postal address indicated above;

(b) using the contact form on our website;

(d) by email, using the email address published on our website.

15. Data protection officer

15.1 The contact email of our data protection officer is: annsullivan@annsullivanperu.org.