Introduction 

We rely on the generosity and support of everyday individuals to act so dolphins can live free from suffering. That is why in this policy, we are transparent about why we need the personal data we request when you engage with us and how we will use it.

We take protecting your privacy very seriously and we will always take all reasonable steps within our power to make sure your data is safe, handled responsibly and in line with the laws that apply to us. 

Please read this Policy carefully, along with our Terms of Use and Cookies Policy, to understand how we collect, use and store your personal data, and the conditions that apply when using the Site or the Content. 

References to we, us, our, Action for Dolphins or AFD are references to Australia for Dolphins Limited, trading as Action for Dolphins. Action for Dolphins is incorporated in Australia and registered as a charity with the Australian Charities and Not-for-profits Commission (ACNC). Action for Dolphins’ headquarters is at 17/31 Queen Street, Melbourne, Victoria, Australia. 

If you have any questions please contact us. 

 

When we collect personal data 

The most common scenarios when we collect personal data from you are when you: 

  • Sign one of our petitions or pledges 
  • Make a donation to us or become a recurring donor
  • Subscribe to our mailing list 
  • Buy a product from us (e.g. from our online shop) 
  • Apply to work with us or volunteer with us
  • Enter into a contract with us 
  • Interact with us by visiting or commenting on one of our websites or social media pages. Using tools such as cookies and online identifiers, we collect personal data about you
  • Contact us, request information from us, give us feedback, make a complaint, or join a campaign
  • Contact us or become involved with us in any other way than as stated above.

What personal data we collect

The personal data we collect and process depends on the context of your interactions with us, the choices you make and the features you use. The personal data we may collect about you include, but is not limited to, the following:

  • Name 
  • Email address
  • Phone number
  • Mailing and billing address
  • Age or dates of birth 
  • Financial and credit card information which you give to us when making a donation or purchase. All payment data is stored in a PCI-DSS compliant platform.
  • If you make a donation as a tribute to someone else, we’ll need their name and email address to send them the tribute. We will not contact them about anything else unless they ask us to
  • Communication preferences 
  • Product purchases, donations and associated history
  • Information you enter onto our website, including information to take part in a campaign or event
  • Records of your donation history, purchase history, communications history or campaign action history
  • Images, photographs or videos if you take part in an event or volunteer with us
  • Details of your visit to our websites and information you enter onto our website
  • Automatically collected information, such as the IP address you use to access the website, IP geolocation, the device you use, your browser type, operating system, country, location, language preferences, referring URLs, version and any urchin tracking module (UTM) parameters and other technical information. 
  • The following additional details about employees, contractors and volunteers: employment history, education history and their interests
  • Any other details in which you give us including your reasons for supporting us.

We might also obtain personal data about individuals who may be interested in giving major gifts to organisations like ours. In these limited cases only, in addition to information you give us directly, we may also collect information from publicly available sources about your work,  interests and philanthropic activities.  

If you apply for a job with us (paid or voluntary) we may collect special categories (sensitive personal data) of information from you. If we seek to collect sensitive personal data from you as part of the application process, you will be provided with separate privacy information when this type of information is requested so you are aware of how your data will be collected, used and stored. 

 

How we collect personal data

Collected from you

We collect personal data that you voluntarily provide to us. For example, we collect and process the data you provide when you make a donation to Action for Dolphins, sign a pledge or petition, or complete the contact us form on our website.  

Automatically collected

We get data from automated technologies. A key example is if you interact with an email we send you, browse our website or click a link we are sharing with you. We primarily process this information to maintain the security of our charity, ensure the content we provide is relevant to people, and for internal analytical and reporting purposes. 

Like many organisations, we collect information through cookies and similar technologies. If you don’t want cookies, you can set your browser to notify you when you receive one, then choose to decline it. Please read our Cookies Policy for more information and to manage your cookies preferences. 

Social media

We may obtain your personal data through your use of social media platforms such as, but not limited to, Facebook, Instagram, Twitter, TikTok, Pinterest or LinkedIn, depending on your settings or the privacy policies of these social media services. To change your settings on these services, please refer to their privacy policies which will tell you how to do this. 

Other sources

In a limited number of cases, we may use desktop and online research, profiling and screening techniques to analyse your personal data to create a profile of your interests and preferences. We do this so that we can contact you with information relevant to you, to be prepared for when we meet you, or to help us find others like you who might like to show their support and to provide more relevant marketing offers. This allows us to target our resources more effectively. 

Such information is compiled using publicly available data about you, for example addresses, listed directorships, social media posts, newspaper articles or typical earnings in a given industry. This helps us understand the background of the people who do or may support us. It also helps us to make appropriate requests for gifts to supporters who may be able and willing to give more than they already do and/or leave us a gift in their will. Collating this publicly available information helps us better understand your motivations and preferences enabling us to deliver a more targeted and relevant donor experience. Additionally, it enables us to raise more funds, sooner, and more cost-effectively than we otherwise could. 

 

Why we process your personal data 

We only process your personal data when we have a valid legal reason to do so under applicable law. The reasons we process your personal data are as follows:  

  • Consent: We may process your personal data if you give us your valid consent to do so (e.g. you give consent to join our mailing list). You can withdraw your consent at any time by contacting us or clicking the unsubscribe link in the email communications we send you. 
  • Legitimate interests: We may process your personal data when we believe it is reasonably necessary to achieve our legitimate interests and those interests do not outweigh your fundamental rights and freedoms. Examples include processing your donations, pledge or petition, developing and displaying relevant advertising content, administering our charity and understanding the effectiveness of our campaigns and communications. 
  • Performance of a contract: We may process your personal data where we need to perform the contract we are about to enter into or have entered into with you (e.g. processing your purchase or donation).
  • Legal obligations: We may process your personal data where we believe it is necessary for compliance with our legal obligations (e.g. cooperating with a law enforcement body or defending our legal rights). 
  • Vital interests: We may process your personal data where we believe it is necessary to protect your vital interests or the vital interests of a third party (e.g. where there are potential threats to the safety of any person). 

We will generally process your personal data in the following scenarios. 

Process signing a pledge or petition 

When you sign a pledge or petition, the personal data you provide is used to apply your support for that petition or pledge, and notify any intended recipients of your support for the call to action. 

Process your donations 

When you generously make a donation to us, we will process the personal data we collect during this interaction to administer the donation and help us run the charity effectively. This involves sending your details to a PCI DSS compliant payment gateway provider to process the donation. 

As part of our legitimate interest in running the charity and keeping donors informed, we will communicate with you so we can send you your donation receipt, keep you up to date with our work and thank you for your support. If you provide your phone number, we’ll send you periodic text messages and phone calls regarding the administration of your donation. We will not use your phone number for marketing purposes unless we have your express consent to do so. 

If you make a donation as a tribute to someone else, we’ll need their name and email address to send them the tribute. We will not contact them about anything else unless they ask us to. 

Join our mailing list and send you marketing communications 

In order to achieve our mission, we need people like you to support us, and to gather your support we need to be able to contact you.

We will always ask for your consent to join our mailing list, and in turn receive marketing materials from us. We will only send you marketing materials by email, SMS, post or phone if you have given us consent to do so. 

If you join our mailing list, the types of communications we may send include, but are not limited to, updates about our campaigns, ways you can support us through advocacy and donations, advocacy work that is building traction in marine conservation around the world, our latest blogs posted on our website, and events you might be interested in attending. 

You are able to withdraw your consent and unsubscribe at any time by following the subscription links on any marketing email we send you or by contacting us using any of the details below. You can also use these options to change your communication preferences. We will always give you an opportunity to opt-out in every communication we send to you via email. 

Changing your marketing preferences will not affect the communications we send you in relation to administering your donation. 

We may invite you to participate in surveys or market research to help us improve our website, fundraising, services, and strategic development. Participation is always voluntary.

Deliver targeted advertising to you 

We process personal data to develop and display personalised content and advertising tailored to you. This is to help us ensure that the ads we show are relevant and focused on people who are most likely to be interested in them. 

Depending on your settings and the privacy policies for social media and messaging services like Facebook, Instagram, LinkedIn and Twitter, you might give us permission to access information from those accounts or services. For example, we occasionally participate in Meta’s “Custom Audience” program which enables us to display adverts to our existing or potential supporters via Facebook and Instagram. We provide personal data such as your email address to Meta to enable them to determine if you are a registered account holder with them. Our adverts may then appear on your Facebook or Instagram account. Your data is sent in an encrypted format that is deleted by Meta if it does not match with a Meta account. For more information, please read Meta’s Privacy Policy

We may carry out research to determine whether an individual could be a potential major donor. We may use publicly available information from third party sources to undertake this research and identification. 

You have the right to object to us using your personal data for marketing purposes at any time. You can do this at any time by contacting us. 

Understand the effectiveness of our activities and communications

We may occasionally process personal data to better understand our supporters,  identify trends and better tailor our communications and offerings. We may occasionally for the purposes of our legitimate interests use your personal data to conduct profiling of our supporters or potential supporters. This will help us target communications in a more focused, efficient, and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You have the right to object to us using your personal data for marketing purposes at any time. You can do this at any time by contacting us.

Engagement and improvement of our website and social media

We may use your personal data to provide you with access to our website and social media pages, personalise your experience, and improve and develop the website further. We use cookies and similar technologies to access and store data. Please read our Cookies Policy to learn more about how we use these technologies. 

Processing your purchases  

When you purchase an item from our online shop, we will process the personal data we collect during this interaction to process your order, payments or returns. This involves sending your details to a PCI DSS compliant payment gateway provider to process the payment for the order, and to our suppliers so they can ship your items to you. 

Administering our charity 

To deliver our charitable objectives and keep your data safe and secure, we need to undertake certain processing activities to govern and operate our charity. Some key examples include: 

  • Send you details about our campaigns and how you can support our mission
  • Processing a record of who our supporters are, your relationship with us, and your history of communications, purchases and donations with us 
  • Reviewing our database of supporters for historical and statistical purposes
  • Processing your personal data if you have contacted us or asked us a question
  • Processing your request (e.g. for further information about our activities, or to allow for communication with another user or organisation) 
  • Taking steps to prevent and monitor fraud, knowing our donors, and taking steps to ensure there is no misuse of services or money laundering
  • Essential internal and external record keeping purposes
  • Send any administrative details or requests to you (e.g. in relation to your card details, or changes to our terms) 
  • Other activities involved with administering the charity, such as for recruitment, maintaining employee records, processing invoices, applying for grants and reconciling accounts.

Apply to work with us or volunteer with us

If you apply to work or volunteer with us, we will need to process your personal data to process your application. The personal data we may process includes name, nationality, contact details, education and work experience, information collected as part of your interview process, background check information and/or other application data. As part of this process, may collect sensitive personal data from you. If we seek to collect sensitive personal data from you as part of the application process, you will be provided with separate privacy information when this type of information is requested so you are aware of how your data will be collected, used and stored. 

We will use the personal data we collect for this purpose to process your application, to determine your eligibility for the role you have applied for, to comply with the law and our obligations, to communicate with you and third parties and/or to carry out background checks.  

If you apply to work or volunteer with us we may collect special categories (sensitive personal data) of information from you. If we seek to collect sensitive personal data from you as part of the application process, you will be provided with separate privacy information when this type of information is requested so you are aware of how your data will be collected, used and stored. 

If you commence a role with us (paid or voluntary), your personal data will be processed in accordance with your engagement contract and other applicable human resources policies we have from time to time. 

Enter into a contract with us 

We will process your personal data as required to carry out our obligations arising from any contracts entered into between you and us.

Responding to you

If you contact us with a query, request information from us, give us feedback or make a complaint, we may process your personal data to respond to you and solve any potential issues you may have. 

Legal and regulatory obligation

Where we are subject to a legal or regulatory obligation, we may process your personal data to fulfil that obligation.

 

Who we share your personal data with

As with other charities, we often appoint specialist providers to help us carry out our objectives and we may share your personal data with those third party providers as part of that process. 

If these activities involve the processing of your personal data, we have contracts in place with those providers which are designed to help safeguard your personal data. As part of those agreements the provider agrees to respect the confidentiality and security of your information and to treat it in accordance with the law. We only permit suppliers to process your personal data for specified purposes and in accordance with our instructions. 

The categories of third party providers we may share personal data with are providers that offer ad networks, finance and accounting platforms, affiliate marketing programs, communication and collaboration tools, payment processors, social networks, website hosting service providers, customer relationship management and marketing tools, user account registration and authentication services  plus government or regulatory organisations. 

 

Keeping personal data safe 

We maintain appropriate technical and organisational controls to protect your personal data. For example, our online forms are always encrypted, our network is protected and routinely monitored. Within our team only those who have a business need to access your information and who are trained in handling personal data securely will have access to your information. 

We 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. 

While we hope it will never happen, we have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are required to do so.

Despite all of our precautions however, no data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect your personal data, we cannot guarantee the security of any data which you disclose to us and so wish to draw your attention to this so that you do so at your own risk. You should only access our services within a secure environment. 

Our website may, from time to time, contain links to third party websites. If you follow a link to any of these websites, please note that these websites will have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

Retention of personal data 

We will only keep your personal data for as long as is necessary for the purpose for which it is collected, which may include the purpose of satisfying any legal, accounting or reporting requirements. 

 

Personal data from minors 

We do not knowingly solicit data from, or market to, children under 18 years of age. By using any services offered by Action for Dolphins, you represent that you are at least 18 years old. If we learn that personal data from a user less than 18 years of age has been collected, we will deactivate that user’s account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from a person under the age of 18 years, please contact us. 

 

Your rights

In some regions, like the European Union, United Kingdom and Canada, you have various rights over your personal data under applicable law. These rights are summarised below. 

Right to transparent communication

You have a right to receive certain minimum information from us regarding the collection and processing of your personal data. We have an obligation to communicate this to you in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

To give effect to this right, we let you know the reason for processing your data at the time we collect it from you. We do this with the use of privacy statements, collection notices and by providing links to this Privacy Policy. 

Right to basic information

You have the right to be provided with information about AFD’s identity, the reasons AFD processes your personal data and other relevant information necessary to ensure the fair and transparent processing of your personal data. We give effect to this right by including all of these details in this Privacy Policy. 

Right of access 

You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you. 

If you would like to receive a copy of the personal data we hold about you, please contact us. When your request has been received and we have verified your identity, your personal data will be supplied to you in a commonly used electronic format unless you tell us otherwise.

We will respond to your request as soon as possible or at the latest within one month. You will not have to pay a fee to access your personal data however we reserve the right to 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.

Right of rectification

You have the right to rectify any inaccurate personal data we hold about you. You can request that we correct, update or complete any inaccurate personal data we hold about you simply by contacting us. Please note that in certain circumstances we may need to verify the accuracy of the new data you provide to us. 

Right to erasure of your personal data 

You have the right for your personal data to be erased in the following circumstances:

Your consent is the legal basis for processing your personal data, you withdraw your consent, and no other lawful purpose exists

Where we have asked you for consent to process your personal data, you may withdraw that consent at any time by contacting us on the details below, or updating your communication preferences in the emails we send you. 

You exercise the right to object to the continued processing of your personal data, and we have no overriding grounds for continuing the processing

If you feel that our processing of your personal data under the legitimate interest condition impacts your fundamental rights and freedoms then you have the right to object to this processing. However, there may be other circumstances where we are able to demonstrate a compelling legitimate reason to continue to process your personal data. Where that reason overrides your rights and freedoms we may refuse your objection. 

Your personal data is no longer needed for the original purpose and no new lawful purpose exists

Your personal data has been processed unlawfully 

Erasure is necessary to comply with an applicable law

Restrict the processing of your personal data

Where you don’t want us to delete your data permanently but wish for us to stop using it for a certain period of time, you also have the right to restrict the processing. This generally can be requested in circumstances where you have concerns over the accuracy of the personal data we hold or how we are using it. 

Request transfer of your personal data 

In certain circumstances you have a right to request a transfer of your personal data from one service provider to another, such as from one service provider to a competitor. To exercise this right, simply contact us and we will give effect to this right provided we still retain your personal data and we have verified your identity. 

 

Complaints

We are committed to working with you to obtain a fair resolution to any complaint or concern regarding your privacy or our use of your personal data. Please contact us with any questions, complaints or concerns. 

If you have any concerns, you have a right to complain to the data protection authority that applies to you at any time. 

 

Updates to this Policy 

We may update this Policy from time to time without notice to you, so please check it regularly, particularly if you are sending personal data to us. 

This Privacy Policy was last updated on 4 August 2023. 

 

Contact us 

If you have any questions please contact us in any of the following ways: 

Sarah Lucas has been appointed as our GDPDR representative in the United Kingdom and the EU. You can contact Sarah directly regarding the process of your information by Action for Dolphins by emailing at privacy@afd.org.au