PRIVACY POLICY

LIONS CLUB OF COLOMBO LEADS

Last Updated: 25 October 2022

1. Introduction

The Lions Club of Colombo LEADS (“the Club”, “we”, “our” or “us”) respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit our website, www.colomboleads.org, contact us through our online forms, or otherwise communicate with the Club through the website.

As a community service organisation, we may receive enquiries from members of the public, volunteers, donors, project partners, beneficiaries and other individuals interested in our charitable and humanitarian activities.

This policy describes our general privacy practices. The specific information collected depends on the website feature or service you use.

By using our website, you acknowledge that you have had the opportunity to read this Privacy Policy. Where consent is required for a particular activity, we will seek it as appropriate. Nothing in this policy overrides rights or obligations established by applicable law.

2. Information We Collect

We may collect the following categories of information, depending on how you interact with our website.

2.1 Information You Provide Directly

When you submit an enquiry through our contact form or communicate with us by email, we may collect:

• Your name.
• Your email address.
• The subject of your enquiry.
• The contents of your message.
• Any other information you voluntarily include in your communication.

If we provide additional online forms for particular activities, such as volunteer participation, community projects or other service programmes, we may collect further information relevant to the specific activity. The information requested will depend on the purpose of that form.

Please provide only the information necessary for your enquiry or application.

2.2 Technical and Usage Information

When you visit our website, certain technical information may be collected automatically by the website, its hosting environment or associated services. Depending on the configuration, this may include:

• Internet Protocol (IP) address.
• Browser type and version.
• Device and operating system information.
• Pages visited and the date and time of access.
• Referring website addresses.
• Technical logs relating to errors, security and website performance.

We may use this information to maintain website security, diagnose technical problems, prevent misuse and understand general website usage.

2.3 Information from Comments and User Accounts

If the website permits visitors to post comments or create user accounts, we may collect the information submitted through those features.

Comment-related information may include the details entered in the comment form, the IP address and browser user-agent information used for spam detection.

If user registration is enabled, information associated with an account may include the username, email address and other details entered in the user’s profile.

These features may not be available to every website visitor.

2.4 Information Relating to Community Service Activities

If you register for or enquire about a Club activity through a dedicated online form, we may collect information necessary to administer that activity.

For example, a particular programme may require contact details, school information, eligibility information or other relevant details.

Where a programme involves health services, medical information or registrations concerning children, we will seek to limit collection to information reasonably necessary for the relevant purpose and apply appropriate safeguards.

Please do not submit medical records, identity documents or other sensitive information through the general contact form unless specifically requested through an appropriate process.

3. How We Use Your Information

We may use personal information for the following purposes:

• To receive, review and respond to enquiries and comments.
• To communicate with individuals who contact the Club.
• To administer relevant community service programmes and activities.
• To coordinate volunteer participation and communications where applicable.
• To maintain, operate and improve our website.
• To protect the website against spam, fraud, unauthorised access and other security threats.
• To maintain appropriate administrative records.
• To comply with applicable legal obligations.
• To address complaints, disputes or requests concerning personal information.

We will use personal information for purposes reasonably connected with the purpose for which it was collected, or for another purpose where permitted by applicable law.

We do not treat the submission of a general contact form as automatic consent to receive newsletters or promotional communications.

4. Legal Basis for Processing

Where required by applicable law, we will ensure that the collection and use of personal information has an appropriate legal basis.

Depending on the circumstances, this may include your consent, responding to a request you have made, carrying out an activity you have requested, complying with a legal obligation or another lawful basis available to the Club.

Where processing relies on consent, you may withdraw that consent subject to applicable legal requirements. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

5. Cookies and Similar Technologies

Our website may use cookies and similar technologies to support its functionality, security and performance.

Cookies are small files stored on your device by a website. The cookies used depend on the website features and services enabled.

5.1 Essential Cookies

Some cookies may be necessary for website functions, including authentication, security and maintaining a session.

If administrative login or account functionality is enabled, WordPress may use cookies to support these features.

5.2 Comment and Preference Cookies

If visitors can leave comments, the website may offer to remember their name, email address and website address in cookies for convenience.

The duration of these cookies depends on the website configuration.

5.3 Analytics and Third-Party Cookies

If analytics tools, embedded content or other third-party services are enabled, they may use cookies or similar technologies to collect information about website usage and interactions.

Where required, we will provide appropriate information and obtain consent before using non-essential cookies or similar technologies.

You can manage cookies through your browser settings. Blocking certain cookies may affect the availability or functionality of some website features.

6. Comments and Spam Detection

If comments are enabled on our website and you submit a comment, the information entered in the comment form may be collected together with technical information used to identify spam or abusive submissions.

An anonymised string generated from your email address may be provided to the Gravatar service to check whether a profile image is associated with that address.

Gravatar is operated by Automattic. You can read its privacy policy at:

https://automattic.com/privacy/

If your comment is approved, any associated profile image may be visible publicly alongside the comment.

Please remember that information published in a public comment may be viewed, copied or shared by other people.

7. Media and Photographs

Our website may display photographs, videos and other media relating to Club activities, community projects, events and humanitarian initiatives.

Where photographs or other media identify individuals, we will seek and use appropriate permissions where required and handle the material in accordance with applicable law and relevant Club practices.

If you upload images to the website through a feature that permits uploads, you should avoid including unnecessary embedded location information, such as GPS coordinates in image metadata.

Publicly available images may be downloaded or copied by third parties. We cannot guarantee that material published on the internet will not be copied or redistributed by others.

If you believe an image or other material published on our website raises a privacy concern, please contact us so that we can review the matter.

8. Embedded Content from Other Websites

Our website may include embedded content or links from third-party services, such as videos, maps, social media posts, images or other external resources.

When you interact with embedded content, the relevant third-party provider may collect information about your device, browser or interaction. Depending on its service and your account settings, that provider may also use cookies or similar tracking technologies.

Such third-party services operate under their own privacy policies and terms. We do not control their independent data collection practices.

We encourage you to review the privacy policies of third-party providers before interacting with their embedded content.

9. Sharing and Disclosure of Personal Information

We do not sell personal information to third parties.

We may disclose personal information in limited circumstances, including:

9.1 Service Providers

We may share relevant information with service providers who assist us in operating and maintaining the website or delivering associated services. These may include website hosting providers, email services, security tools, spam detection services and other technical providers.

Such access should be limited to what is reasonably necessary for the relevant service.

9.2 Club Administration and Project Coordination

Where necessary, relevant information may be shared with authorised Club representatives or individuals responsible for responding to enquiries or administering a specific activity.

Where a programme involves a partner organisation, information may be shared with that organisation only where necessary and subject to an appropriate lawful basis and applicable safeguards.

9.3 Legal and Security Requirements

We may disclose information where reasonably necessary to comply with a legal obligation, respond to a lawful request, protect the rights or safety of individuals, investigate suspected misuse or protect the security of our website.

9.4 International Service Providers

Some website or communication service providers may process or store information outside Sri Lanka.

Where personal information is transferred internationally, we will consider applicable legal requirements and appropriate safeguards.

We do not authorise third parties to use personal information obtained through the Club for unrelated purposes merely because they provide a service to us.

10. How Long We Retain Personal Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal, administrative and security requirements.

Retention periods may vary depending on the type of information and the circumstances.

• Contact form enquiries: Retained for the time reasonably necessary to respond to the enquiry and maintain relevant correspondence.
• Comments: If comments are enabled, comments and associated metadata may be retained to support moderation and spam prevention.
• User accounts: If registration is enabled, account information may be retained while the account remains active and for any additional period reasonably required for legitimate administrative or legal purposes.
• Technical and security logs: Retained for a period appropriate to security monitoring, troubleshooting and investigation.
• Project and programme records: Retained for the time reasonably necessary to administer the activity, maintain appropriate records and meet applicable obligations.

When personal information is no longer required, we will take reasonable steps to delete it, anonymise it or otherwise dispose of it appropriately, subject to applicable retention requirements.

11. How We Protect Personal Information

We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, alteration, disclosure or misuse.

Depending on the circumstances, these measures may include access controls, website security measures, software updates, backups and other appropriate safeguards.

However, no website, electronic transmission or data storage system can be guaranteed to be completely secure.

Visitors should avoid transmitting unnecessary confidential or sensitive information through general website forms or ordinary email.

If you suspect that information submitted to the Club has been misused or disclosed without authorisation, please contact us using the details provided below.

12. Your Privacy Rights

Subject to applicable law and the circumstances of the processing, you may have the right to:

• Request information about the personal data we hold about you.
• Request access to your personal information.
• Request correction of inaccurate or incomplete information.
• Request deletion or erasure of personal information where applicable.
• Withdraw consent where processing is based on consent.
• Object to or request restriction of certain processing where the law provides such rights.
• Raise a concern or complaint about the handling of your personal information.

These rights are subject to applicable legal conditions and exceptions. We may need to verify your identity before responding to a request.

To exercise a privacy right, please email us at info@colomboleads.org with the subject line “Privacy Request” and explain the nature of your request.

We will review and respond to your request in accordance with applicable requirements.

13. Children’s Privacy

Our website may publish information about community service activities involving children, including educational assistance and other humanitarian programmes.

We recognise the importance of protecting children’s privacy.

Where information about a child is required for a specific programme, we will seek to collect only information reasonably necessary for that programme and apply appropriate safeguards.

Where required, we will seek permission from a parent, legal guardian or other appropriately authorised person before collecting, using or publishing information about a child.

Parents or legal guardians who have questions or concerns about information relating to a child may contact us using the details provided in this policy.

14. External Websites and Links

Our website may contain links to websites operated by other organisations, including Lions Clubs International, community partners, public institutions and service providers.

These links are provided for information and convenience. Once you leave our website, the privacy practices of the external website will apply.

The Club is not responsible for the privacy policies, security practices or content of websites operated independently by third parties.

Please review the relevant third-party privacy policy before providing personal information to an external website.

15. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes to our website, the information we collect, our operational practices or applicable legal requirements.

Any revised version will be published on this page, together with an updated “Last Updated” date.

We encourage visitors to review this page periodically to remain informed about how personal information is handled.

16. Contact Us

If you have questions about this Privacy Policy, wish to exercise a privacy right or have a concern about how your personal information is handled, please contact us:

Lions Club of Colombo LEADS

Website: https://www.colomboleads.org/

Email: info@colomboleads.org

Please use the subject line “Privacy Request” when contacting us about personal information.

We appreciate your trust in the Lions Club of Colombo LEADS and remain committed to treating personal information responsibly and respectfully.