Food Culture Alliance Privacy Policy

1. Who are we?

The Food Culture Alliance (“Alliance”) is an alliance of organisations working to champion the role of culture to transform society’s consumption of food.

The website of the Alliance (www.foodculturealliance.org) is legally owned and operated by the Global Alliance for Improved Nutrition (“GAIN” “we”, “us”, “our”). GAIN is a non-profit foundation, duly constituted under the laws of Switzerland. GAIN’s registered office is: Rue Varembé 7, 1202 Geneva, Switzerland. GAIN is a data controller for the purpose of data protection legislation.

GAIN respects confidentiality and the privacy of our online visitors. This Privacy Policy explains when and why we collect personal information, how we use it, when we may share this data and how we keep it secure.

2. What data do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect and store the following types of personal information about you when you use our website or by corresponding with us (for example, by email). This includes information you provide when registering to use our website, signing up to our newsletter, or sharing any data via our social media functions. The information given to us may include, but is not limited to:

• Identity data: this includes your title and Organization in which you work, name, telephone number and email address.

• Usage Data: this includes information about how you use our website and services we provide.
• Technical Data: This includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data: We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3. Legal basis for processing

Our processing of your personal information is necessary:

• For the purposes of legitimate interests pursued by us.
• In order to comply with a legal obligation to which we are subject; or
• For the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts.

In relation to any processing of special categories of personal data, we will generally rely on obtaining specific consent from you at the time, unless there is a legal requirement for us to process such information.

4. Legitimate interests

Where our processing is based on the legitimate interest grounds described above, those legitimate interests are:

• Collecting personal information to provide you with a smooth and efficient experience;
• Running our organisation;
• To make sure you receive updated information on the Alliance activities;
• To provide the services you have requested;
• For our own marketing, research and development.

5. How will we use the information we collect?

We use your information to:

• Keep you informed about the Alliance – our projects and events which we think you may find interesting.
• Carry out our obligations arising from any agreements entered between you and us.
• Communicate with you.
• Provide you with marketing communications (where we have the right to do so).
• Administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• Keep our website safe and secure;
• Comply with legal and regulatory obligations; and
• For security and to check your identity.

6. How long will we keep your information?

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of data to fulfil our statutory obligations. We will hold your personal data on our systems for as long as is necessary for purposes set out above, or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.

Where we are permitted to send you direct marketing communications, we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us.

If you opt out from marketing communications, we will retain your information to enable us to respect your wish to not be contacted for marketing purposes.

7. Data Security

GAIN takes data protection seriously and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

8. Sharing your information

The personal information you provide to us may be shared with the following categories of companies, if this is necessary to provide you with our services, respond to your enquiries or for any of the purposes described in this policy: third party organisations; agents; contractors; service providers; or affiliated companies.

Other than the third-party services GAIN uses as part of our marketing and communications efforts (detailed below ‘Third Parties’), GAIN also shares your data with our communications agency, Shape History. Shape History is a social Impact communications agency, and for the purpose of data protection legislation is a data processor. Shape History’s registered office is: 1st Floor, 77 Fortess Rd, London NW5 1AG, United Kingdom.

Please note, we may also share your personal information with: law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and other entities, should we plan to merge with or be acquired by that entity, or if we undergo a re-organisation with that entity.

9. International transfers

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or Switzerland. It may also be processed by staff operating outside the EEA who work for us, or for one of our service providers.

When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the European Economic Area or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing.

In the case of transfers by us, we may also transfer your information where:

• the transfer is to a country deemed to provide adequate protection of your information by the European
  Commission; or
• where you have consented to the transfer.

10. Your right as data subject

At any time, you have the right:

• to request access to or a copy of any personal data which we hold about you;
• to ask for a rectification of your personal data, if you consider that it is inaccurate;
• to ask us to delete your personal data, if you consider that we do not have the right to hold it;
• to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• to ask us to stop or start sending you marketing messages (e.g. our newsletters) at any time by using the below contact details;
• to restrict processing of your personal data;
• to data portability (moving some of your personal data elsewhere) in certain circumstances;
• to object to your personal data being processed by us on legitimate interest grounds and other certain circumstances; and to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations with regards to your rights as a data subject.

11. Cookies

“Cookies” are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit the site. GAIN uses Cookies for our own internal purposes, to track how users navigate through our website.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. The “Help” or “Internet Settings” functions within your browser should tell you how. Please be aware that if you select to refuse or restrict cookies this may impact on the functionality of our website. You can find more information about cookies at www.allaboutcookies.org.

We use traffic log cookies to identify which pages are being used (in particular Google Analytics). This helps us analyse data about web page traffic and improve our site in order to tailor it to user needs. We only use this information for statistical analysis purposes; these cookies cannot be used to identify individuals.

We use information resulting from cookies in order to:

• ascertain how users are using our website and if we can improve user experience;
• facilitate users’ ability to navigate through the website;
• personalise the services we offer by understanding your preferences and by establishing which areas are most relevant to you.

Third Parties

We use a number of third-party providers to support our communications and marketing. Each of these services sets its own cookies and privacy policy when using their platform.

• We use Google Analytics to track website usage and YouTube to host videos. You can read Google’s privacy policy here: https://policies.google.com/privacy?hl=en-US
• We use social media platforms such as Twitter/X and LinkedIn to reach audiences. These platforms also allow us to target audiences with paid advertising. You can read Twitter/X’s privacy policy here, and LinkedIn’s privacy policy here.
• Another service we use is provided through MailChimp, which helps us to design email newsletters, share them on social networks and integrate with our other services. Personal data provided to GAIN when signing up to our newsletter is also stored here. You can read Mailchimp’s privacy policy here.

Links to other websites

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy or notice of every website you visit

12. Contact

Please contact us via email contact@foodculturealliance.org. if you:

• Have any questions, comments or concerns about how we handle your Personal Data;
• Would like us to stop using your information;
• Want to exercise any of your rights as set above in section 10; or
• Want to make a complaint;

If you have any concerns about our use of your information, you also have the right to make a complaint to the relevant supervisory authority, which regulates and supervises the use of your personal data in your country of residence.

13. Changes to this Privacy Policy

We keep this Privacy Policy under regular review, and it may be periodically updated. Updates to this Privacy Policy will be posted on this page – please check back from time to time. If there are significant changes to this Notice, we will use reasonable efforts to contact you directly to inform you through the appropriate means. This Privacy Policy was last updated on 7 November 2023. Please contact us If you have further questions about this or the way in which we handle your personal information at contact@foodculturealliance.org.