Privacy Policy

For the purposes of applicable data protection laws, the data controller of this website is Smile Train, Inc., a 501(c)(3) non-profit recognized by the Internal Revenue Service of the United States and with a registered office of 633 Third Ave., 9th Floor, New York, NY 10017 USA.

This Privacy Policy explains the collection, use and disclosure of personal data through our website: https://www.smiletraindubai.org/ (“Website”) and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand the ways in which we use, share and protect your personal data. We are committed to ensuring that your privacy is protected and respected.

In order to fully understand your rights we encourage you to read this Privacy Policy as well as our Terms of Use. Smile Train reserves the right at any time and without notice to change this Privacy Policy simply by posting such changes on our Website. Any such change will be effective immediately upon posting.

What Personal Data We Collect and How We Use That Information

Personal Data is information from which you can be identified as an individual, whether directly or indirectly, such as your name, address, email address, company name, phone number, or other information that is specific to you (“Personal Data”).

We collect these types of Personal Data:

1. Standard web server traffic pattern information - which is comprised of general traffic, site usage, and length of stay information which is collected and stored in log files. This type of information is shared externally, if at all, only on an aggregated basis.
2. Information collected through our registration forms - Our registration forms require users to give us contact information that may include name, email address, format preference (HTML vs. Text), address, browser type, IP address, location, interests and similar information. We use this information to contact you should there be a question about your donation and we also use this information to personalize communications to you to keep you informed about our programs and progress.
3. Automated technologies or interactions - We also collect some information about your internet visits, which are not directly connected to any personally identifiable information about you. This includes IP address, traffic data, location data, weblogs, history of resources accessed on our Website and information on what websites you visited before accessing our Website. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies (see below).

We do not collect special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email or text message.

Purpose for collecting your Personal Data

Smile Train collects your Personal Data for the following purposes:

• To process your charitable donations;
• For internal record keeping;
• To periodically send promotional emails about new campaigns or other information which we think you may find interesting using the email address which you have provided, where you have consented to being contacted for such purposes;
• To provide you with feedback on the project you have chosen to donate to; and
• To analyse and improve our Website.

How long will your Personal Data be held for

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For further information on retention periods, please contact us using the details provided at the end of this Privacy Policy.

How do we store your Personal Data

Smile Train securely stores your data in a range of different places, including on your registration form, in our management systems and in other IT systems.

What are your data protection rights?

You may wish to exercise one or more of the following legal rights. You can do so by contacting us using one of the methods set out at the end of this Privacy Policy.

• The right to access. You have the right to request copies of your personal data.
• The right to rectification. You have the right to request that Smile Train correct any information you believe is inaccurate. You also have the right to request Smile Train to complete information you believe is incomplete.
• The right to erasure. You have the right to request that Smile Train erases your personal data, under certain conditions.
• The right to restrict processing. You have the right to request that Smile Train restricts the processing of your personal data, under certain conditions.
• The right to object to processing. You have the right to object to Smile Train's processing of your personal data, under certain conditions.
• The right to data portability. You have the right to request that Smile Train transfers the data that we have collected to another organisation, or directly to you, under certain conditions.

Is a fee required?

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What do I need to provide?

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

What is the time limit to respond?

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you would like to exercise any of these rights, please contact us at our email: [email protected] or write to us at our registered office: Smile Train, Inc. 633 Third Ave., 9th Floor, New York, NY 10017 USA.

reCAPTCHA

To protect our Website from spam and abuse, while letting real people pass through with ease, Smile Train utilizes reCAPTCHA. This third party software collects information about users for security reasons – information collected by reCAPTCHA is held in accordance with the Google Privacy Policy.

Automated Clearing House (ACH) Donations on our Website:

Smile Train uses Plaid Technologies, Inc ("Plaid") to gather End User's data from financial institutions. By using our service, you grant Smile Train and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

Use of "Cookies":

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our Website, we may collect information from you automatically through cookies or similar technology.

Our Website may use cookies to enhance your experience while using our Website. Cookies are pieces of information that some websites transfer to the computer that is browsing that website and are used for record-keeping purposes at many websites. Use of cookies makes web-surfing easier by performing certain functions such as saving your passwords, your personal preferences regarding your use of the particular website and to make sure you do not see the same ad repeatedly. Many consider the use of cookies to be an industry standard.

Your browser is probably set to accept cookies. However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our Website will not function properly when you view them.

What types of cookies do we use?

We use the following types of cookies:

• Strictly Necessary - these cookies are essential for our Website to function properly. This category only includes cookies that ensures basic functionalities and security features of the Website. These cookies do not store any Personal Data. If these cookies are blocked or disabled, some of the Website may not operate effectively.
• Non-necessary — any cookies that may not be particularly necessary for the Website to function and are used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. It is mandatory to procure user consent prior to running these cookies on your Website.

For the purposes of applicable data protection laws, the data controller of this website is Smile Train, Inc., a 501(c)(3) non-profit recognized by the Internal Revenue Service of the United States and with a registered office of 633 Third Ave., 9th Floor, New York, NY 10017 USA.

This Privacy Policy explains the collection, use and disclosure of personal data through our website: https://www.smiletraindubai.org/ (“Website”) and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand the ways in which we use, share and protect your personal data. We are committed to ensuring that your privacy is protected and respected.

In order to fully understand your rights we encourage you to read this Privacy Policy as well as our Terms of Use. Smile Train reserves the right at any time and without notice to change this Privacy Policy simply by posting such changes on our Website. Any such change will be effective immediately upon posting.

What Personal Data We Collect and How We Use That Information

Personal Data is information from which you can be identified as an individual, whether directly or indirectly, such as your name, address, email address, company name, phone number, or other information that is specific to you (“Personal Data”).

We collect these types of Personal Data:

1. Standard web server traffic pattern information - which is comprised of general traffic, site usage, and length of stay information which is collected and stored in log files. This type of information is shared externally, if at all, only on an aggregated basis.
2. Information collected through our registration forms - Our registration forms require users to give us contact information that may include name, email address, format preference (HTML vs. Text), address, browser type, IP address, location, interests and similar information. We use this information to contact you should there be a question about your donation and we also use this information to personalize communications to you to keep you informed about our programs and progress.
3. Automated technologies or interactions - We also collect some information about your internet visits, which are not directly connected to any personally identifiable information about you. This includes IP address, traffic data, location data, weblogs, history of resources accessed on our Website and information on what websites you visited before accessing our Website. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies (see below).

We do not collect special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email or text message.

Purpose for collecting your Personal Data

Smile Train collects your Personal Data for the following purposes:

• To process your charitable donations;
• For internal record keeping;
• To periodically send promotional emails about new campaigns or other information which we think you may find interesting using the email address which you have provided, where you have consented to being contacted for such purposes;
• To provide you with feedback on the project you have chosen to donate to; and
• To analyse and improve our Website.

How long will your Personal Data be held for

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For further information on retention periods, please contact us using the details provided at the end of this Privacy Policy.

How do we store your Personal Data

Smile Train securely stores your data in a range of different places, including on your registration form, in our management systems and in other IT systems.

What are your data protection rights?

You may wish to exercise one or more of the following legal rights. You can do so by contacting us using one of the methods set out at the end of this Privacy Policy.

• The right to access. You have the right to request copies of your personal data.
• The right to rectification. You have the right to request that Smile Train correct any information you believe is inaccurate. You also have the right to request Smile Train to complete information you believe is incomplete.
• The right to erasure. You have the right to request that Smile Train erases your personal data, under certain conditions.
• The right to restrict processing. You have the right to request that Smile Train restricts the processing of your personal data, under certain conditions.
• The right to object to processing. You have the right to object to Smile Train's processing of your personal data, under certain conditions.
• The right to data portability. You have the right to request that Smile Train transfers the data that we have collected to another organisation, or directly to you, under certain conditions.

Is a fee required?

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What do I need to provide?

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

What is the time limit to respond?

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you would like to exercise any of these rights, please contact us at our email: [email protected] or write to us at our registered office: Smile Train, Inc. 633 Third Ave., 9th Floor, New York, NY 10017 USA.

reCAPTCHA

To protect our Website from spam and abuse, while letting real people pass through with ease, Smile Train utilizes reCAPTCHA. This third party software collects information about users for security reasons – information collected by reCAPTCHA is held in accordance with the Google Privacy Policy.

Automated Clearing House (ACH) Donations on our Website:

Smile Train uses Plaid Technologies, Inc ("Plaid") to gather End User's data from financial institutions. By using our service, you grant Smile Train and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

Use of "Cookies":

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our Website, we may collect information from you automatically through cookies or similar technology.

Our Website may use cookies to enhance your experience while using our Website. Cookies are pieces of information that some websites transfer to the computer that is browsing that website and are used for record-keeping purposes at many websites. Use of cookies makes web-surfing easier by performing certain functions such as saving your passwords, your personal preferences regarding your use of the particular website and to make sure you do not see the same ad repeatedly. Many consider the use of cookies to be an industry standard.

Your browser is probably set to accept cookies. However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our Website will not function properly when you view them.

What types of cookies do we use?

We use the following types of cookies:

• Strictly Necessary - these cookies are essential for our Website to function properly. This category only includes cookies that ensures basic functionalities and security features of the Website. These cookies do not store any Personal Data. If these cookies are blocked or disabled, some of the Website may not operate effectively.
• Non-necessary — any cookies that may not be particularly necessary for the Website to function and are used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. It is mandatory to procure user consent prior to running these cookies on your Website.

How can you manage cookies?

You can set your browser not to accept cookies, and the below Website tells you how to remove cookies from your browser. However, in a few cases, some of our Website features may not function as a result.

Should you choose to disable or block our cookies on your computer you will need to do this through your browser. Click on the 'Help' menu to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive Personal Data on how to manage cookies.

Sharing your Personal Data

We will not share Personal Data collected through our Website with unrelated third parties, except as provided in this Privacy Policy. We may share Personal Data in the following situations:

• Where it is necessary to provide Personal Data to our trusted third-party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the Website, database storage and management and donation processing, to the extent necessary to supply the services to you;
• Where it is necessary to provide selected third parties, including analytics and search engine providers that assist us in the improvement and optimisation of the Website;
• Where it is necessary to comply with the law or enforce any legal rights. For example, we may disclose Personal Data about you as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process, to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations; or
• Where we believe that we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property or safety of us or others.

We may occasionally wish to share your Personal Data, including your email address, with our partner organisations as part of specific initiatives. Where this is the case, we will ask you for your consent in advance to share your Personal Data in this way. We will not share any of your Personal Data with our partner organisations unless you consent by opting-in.

Security:

All information provided to Smile Train is transmitted using SSL (Secure Socket Layer) encryption. SSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. We also protect account information by placing it on a secure portion of our Website that is only accessible by certain qualified employees of The Smile Train. Unfortunately, however, no data transmission over the Internet is 100% secure. While we strive to protect your information, we cannot ensure or warrant the security of such information.

Other Websites:

Our Website contains links to other websites. Please note that when you click on one of these links, you are entering another website for which Smile Train has no responsibility. We encourage you to read the privacy statements on all such sites as their policies may be different than ours.

Contacting Us:

If you have any questions about this Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us: :

Email us: [email protected]

Or write to us at: Smile Train, Inc. 633 Third Ave., 9th Floor, New York, NY 10017 USA.

Changes to our privacy policy:

We may change this policy from time to time by updating this page. You should check this page to ensure that you are happy with any changes. This privacy policy was last updated February 2023.