PRIVACY POLICY

 

Holsby Bible School & Retreat Center CampHolsby

(Stiftelsen Missionssällskapet Fackelbärarna)

 

Holsby Bible School & Retreat Center / CampHolsby (hereafter “Holsby” or “we”) is committed to protecting the privacy and integrity of your personal data. The purpose of this privacy notice is to inform you about how we handle your personal data. We handle your personal data in accordance with all currently applicable government regulations for data protection.

 

  1. Some definitions: What do these terms mean?

 

Personal data: Personal data relates to a living individual who can be identified from that data (e.g. home address, personal email address, passport number, etc.). Online identifiers include IP addresses and cookies. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

 

Special categories personal data: The GDPR refers to sensitive personal data as ‘special categories of personal data’ (Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

 

Processing: This means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

 

  1. Who is responsible for your personal information?

Holsby Bible School & Retreat Center / CampHolsby (Stiftelsen Missionssällskpet Fackelbärarna), Swedish organization number 82 7500-4730, at Brunnsvägen 31; 57453 Holsbybrunn; Sweden is the Data Controller (contact details below). This means Holsby decides how your personal data is processed and for what purposes.

 

  1. Which specific personal details does Holsby process?

We process the following categories of your data (if you have submitted this information to us):

  • Your name, sex and date of birth;
  • Your postal address;
  • Your phone and email address;
  • Where relevant, your parent/guardian and their contact details.

 

When you apply to attend Holsby Bible School as a student, in addition to the above:

  • Your personal image (photo);
  • Your education records;
  • Your career and employment history;
  • Your marital status and details of any children;
  • Your nationality, passport and person number/social security number;
  • And other needed identification documents and/or information.

 

If you are a donor to Holsby:

  • Your donation details.

 

We process special categories of personal data including, without limitation:

  • Your health, including any disability;
  • Dietary requirements.

 

When you apply to attend Holsby Bible School as a student, we additionally process the following special categories of personal data, including, without limitation:

  • Your ethnic origin;
  • Your race;
  • Your religion (including place of worship);
  • Any criminal offences you have committed;
  • Your physical and mental health history.

 

The vast majority of the information we hold is obtained directly from the forms that you have filled in (such as application forms, contact forms, booking forms and registration forms).

 

  1. What is the legal basis for processing your personal data?

 

  1. a) Personal data:

The “GDPR” outlines seven different categories of possible basis for processing personal data (Ch. 1 Art. 6-1 (a-f) and Art. 9-2 (d). Holsby relies on your explicit consent as the main legal basis for processing, where it is not overridden by the interests and rights or freedoms of the data subjects concerned. Where appropriate, Holsby will also process your data on an alternative legal basis, such as the legitimate interests of Holsby or to fulfill Holsby’s contractual obligations with a data subject.

 

  1. b) Special categories of personal data

To the extent we process your special categories of personal data, in addition to pursuing Holsby’s legitimate interests in fulfilling the purposes set out in Section 6 of this Privacy Policy, we have obtained your explicit consent, or it may be necessary for reasons of public interest in the area of public health. More information on lawful processing can be found on the GDPR website (www.gdpr-info.eu).

 

  1. Sharing your personal data
    Your personal data will be treated as strictly confidential and will only be shared with other members of the Holsby staff in order to carry out a service to other Holsby participants, staff, volunteers or friends, or for purposes connected with Holsby’s ministry. We will only share your data with third parties outside of Holsby with your express consent. Please note, however, that we may need to disclose your information to a third party if required by law (for example to government bodies and law enforcement agencies).

 

  1. For what purposes does Holsby process your personal information?

We use your personal data for the following purposes:

  • Communicating with students, guests, staff/volunteers, alumni and current and potential supporters
  • Informing our constituents of Holsby news, activities and events
  • Administering student/participant records
  • Providing benefits and services to students, guests, staff/volunteers, alumni and supporters as specified in our constitution
  • Furthering Holsby’s ministry goals (which includes fundraising and securing the support of volunteers)
  • Managing Holsby employees and volunteers
  • Processing and maintaining records of donations
  • Safeguarding Holsby’s legal rights
  • Fulfilling Holsby’s legal and contractual obligations.

 

  1. What about minors under the age of 16?

For those minor participants in Holsby’s programs who are under 16 years of age, their personal information falls under the category of sensitive data:

  • Written permission from the minor’s parents/guardians is required for any processing of personal information. This permission is given through a separate form that includes the ability to say yes or no to Holsby’s processing of various specific personal details. For insurance and safety reasons, permission from parents/guardians for certain personal information will be required in order to participate in camps, retreats and other Holsby-run activities.

 

  1. How long do we keep your personal data?
    Depending on the specific processing purpose of your personal data, Holsby keeps your personal information for various lengths of time, but no longer than reasonably necessary. Holsby does not keep your data longer than the data protection laws, regulations or accepted standards permit. Data will be kept securely and destroyed when no longer required. We may also decide to archive some data.

 

  1. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  • The right to request a copy of your personal data which Holsby holds about you;
  • The right to request that Holsby corrects any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary for Holsby to retain such data;
  • The right to withdraw your consent to the processing of your special categories of personal data at any time, where consent was the lawful basis for processing such data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
  • The right to lodge a complaint with the appropriate authorities.

 

  1. Transfer of data abroad

Holsby does not transfer personal data outside the EEA.

 

  1. Online application forms

Third-party providers: CubeMedia and PayPal.

We use third-party providers to collect data on our behalf, including if you are attending Holsby as a Bible school student, or if you wish to make a donation to us. These third-party providers are data processors for us and only process personal information in accordance with our instructions.

 

  1. Electronic newsletter

Third-party provider: MailChimp

We use a third-party provider to deliver our e-newsletters. We use industry standard technologies to gather statistics around email opening and clicks, to help us monitor and improve our e-newsletter.

 

  1. Social media

Third-party providers, including: Facebook, Instagram, Twitter, Vimeo and YouTube

If you send us private or direct messages via social media, the messages will be stored by a third-party provider. However, they will not be shared with any other organizations.

 

  1. Cookies

Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site by placing small text files on your computer when you visit the website. While Holsby does not, at this time, use cookies, we reserve the right to implement them in the future. Cookies that we might use in the future would help us count visitors to our websites, and monitor whether you have visited our websites previously. You may change your website browser settings to reject cookies, although please note that if you do this it may impair the functionality of our website. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.

 

  1. Security and performance

We use a third-party service to assist in maintaining the security and performance of our website, which requires the processing of website users’ IP addresses to do so. While we take appropriate technical and organizational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.

 

  1. Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

 

  1. Changes to our privacy policy

Please check back regularly to keep informed of updates to this Privacy Policy as you will be deemed to have accepted any changes if you continue to use our website after an update has been posted.

 

  1. Contact Details

We commit ourselves to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously and encourage individuals to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate, and welcome any suggestions for improving our procedures.

 

To exercise all relevant rights, or to address queries or complaints, please contact our Data Protection Representative at privacy@holsby.org.

 

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the appropriate government authorities.

 

This policy was last update 18 May 2018