Privacy Policy

Last Updated: July 2022

​GlobalChoices.org and its affiliates and subsidiaries (collectively “Global Choices,” “we,” “our,” and “us”) is fully committed to protecting any personal information relating to an identified or identifiable natural persons (“Personal Data”) that we process.

​This Global Choices Privacy Notice (“Notice”) describes our collection, use, disclosure, and retention of Personal Data in relation to our website, and your use of the website, our marketing and provision of services, our interactions with you in-person, by calling us, or by mail, and otherwise during the operation of our business. The Notice also explains the ways in which you may, under applicable laws, be able to control our processing of your Personal Data and exercise other rights. This Notice does not apply to Personal Data of members of our workforce in the context of that relationship or job applicants.

​Depending on the way you interact with us, we may occasionally provide you additional information about our processing of your Personal Data addressing specific processing activities and circumstances. We refer to such notices here as “Supplemental Disclosures”. Supplemental Disclosures should be read together with this Notice. However, in the event of any conflict or inconsistency between the terms of the Supplemental Disclosure and this Notice, the Supplemental Disclosure will prevail, but only for the Personal Data processing subject to that disclosure.

​Anonymous, deidentified, and aggregated data, as those terms may be defined under applicable law, are not considered “Personal Data” within the meaning of this Notice.

​This Notice is comprised of the following sections:

1. Personal Data We Collect
2. Why We Process Personal Data
3. Lawful Bases of Processing
4. Disclosures of Personal Data
5. Cross-border Transfers of Personal Data
6. Data Security and Retention
7. Your Choices and Rights
8. Children’s Data
9. Revisions to this Notice
10. Contact Us

​Please note that our website may link to content provided by third parties that we do not control and for which we are not responsible. When you navigate to such content, the relevant third parties may process your Personal Data. We encourage you to read the third parties’ privacy and cookies notices when you leave our website.

1. Personal Data We Collect

​Global Choices or third parties acting on our behalf may collect Personal Data about you from a number of sources. We may collect Personal Data that you provide, such as when you apply to be an Arctic Angel, make a donation, or sign up to receive updates from us. We may also automatically collect Personal Data as you interact with us, such as through cookies and similar technologies on our website, including information such as collecting the IP address from which you visited our site (see further discussion of cookies at the end of this section).

​The types and amount of Personal Data that we collect about any particular individual would depend on the nature of our relationship with that individual and the purposes for which we use the individual’s Personal Data. We collect Personal Data from different categories of individuals, including but not limited to the following:

• Visitors to our digital properties (such as our website and social media)
• Workforce members and volunteers
• Donors

Personal Data That You Provide

​We collect Personal Data that you choose to provide us, such as when you apply to be an Arctic Angel or sign up to receive updates from us, among other interactions.

​Depending on your relationship with us, you might provide us the following categories of Personal Data:

• Identifiers and Contact Data, such as your name, alias, postal address, email address, telephone number, city, state, and country of residence, government-issued identifiers (such as passport number or driver’s license), financial account numbers, and similar identifiers;
• Demographic Data, such as your income levels, marital status, ethnicity, sex, gender, age, sexual orientation, national origin, disability status, citizenship, and work authorization status;
• Commercial Data, such as invoices, payment terms and schedules, financial account information, and information about services rendered;
• Images, Recordings, and Postings, such as images and recordings of your likeness or voice, social media postings, and other communications; and
• Preferences and Survey Responses, such as your preferences regarding communication means and your responses to surveys.

Personal Data That We Collect Automatically

​We may automatically collect information that constitutes Personal Data when you interact with us, such as when you visit our digital properties, read our marketing communications, including emails, contact us, or attend events that we are hosting, among other interactions.

​Depending on your interaction with us, we might collect the following categories of Personal Data:

• Identifiers and Contact Data, such as device identifiers (e.g., IP and MAC addresses, cookie identifiers, device advertising identifiers), email address, phone number, and similar identifiers; and
• Usage and Device Data, such as websites visited, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices used to access our websites and apps, volume of transferred data, location data (e.g., inferred by IP address or obtained through GPS), and interactions with advertisements.

​We may use cookies and related digital tracking technologies (“Cookies”) on our website or otherwise on our digital properties. This may involve us or third parties collecting Personal Data about online activities over time and across third party websites or online services. Please read our Cookie Notice for more information about our use of Cookies. We do not currently respond to web browser Do Not Track signals or similar mechanisms.

Personal Data That We Collect from Third Parties

​We may obtain Personal Data relating to you from third parties, such as when we obtain contact data from social media platforms.

The third parties from which we obtain Personal Data generally fall within the following categories:

• Government sources
• Publicly accessible data
• Social media platforms
• Marketing list suppliers
• Advertising partners
• Analytics providers
• Payment processors
• Data supplementation suppliers
• Business partners, such as event co-sponsors

We collect the following categories of Personal Data from third parties:

• Identifiers and Contact Data, such as name, postal address, email address, telephone number, general location (such as city, state, and country), username, and device identifiers (including cookie identifiers and device advertising identifiers);
• Demographic Data, such as information about income levels, age, sex, gender, sexual orientation, national origin, and disability status;
• Usage and Device Data, such as websites visited, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices used to access our websites and apps, volume of transferred data, location data (e.g., inferred by IP address or obtained through GPS), and interactions with advertisement; and
• Commercial Data, such as details of products and services purchased or sampled and inferences regarding the population segments to which you might belong.

2. Why We Process Personal Data

​The specific purposes for which Global Choices processes an individual’s Personal Data differs based on our relationship with the individual. In general, Global Choices processes Personal Data for the following purposes:

• To conduct legitimate business activities, including but not limited to marketing, promotion, entering into contractual agreements, contracting with third party service providers, and procuring goods or services.
• To deliver our products, goods, or services, including to fulfil your requested transactions and, where necessary, to confirm that you meet an eligibility criteria if the requested product, good, or service is limited to certain groups.
• To communicate with individuals, including responding to questions, queries, and complaints from customers, users, donors, and other individuals, responding to requests for donations, sponsorships, scholarships, or charity, and informing individuals about opportunities with Global Choices.
• To provide information and advertising, such as digital advertising or direct marketing, about our mission, donation opportunities, goods, services, and products that we think may be useful, relevant, or of interest to you.
• To provide training, education, and grants, such as our training and education programs that we provide.
• To evaluate an individual’s candidacy, such as when processing an application to be an Arctic Angel.
• To provide, maintain, develop, and improve our digital properties, including our websites and social media.
• To maintain, improve, and investigate the security of our systems and website.
• To comply with legal obligations.
• To protect the rights, interests, and safety of us, you, and any third parties, and to exercise and defend our rights.
• To create anonymous, deidentified, or aggregated datasets. Such datasets would not be “Personal Data” subject to this Notice. We may use anonymous, deidentified, or aggregated datasets for any purpose.

The additional purposes for which we may process what are deemed special categories of personal data under certain jurisdictions’ laws are as follows to the extent relevant, necessary, and permitted by applicable local law:

• Demographic data – We will use information about your sexual orientation, race, ethnicity, and disability for specific reasons, such as necessary to pursuant Global Choices’ mission.

3. Lawful Bases of Processing

Certain jurisdictions require that we have a lawful basis to justify our processing of your Personal Data. Where applicable, the lawful bases that Global Choices relies upon to justify a particular processing activity may differ from the lawful basis used to justify a different processing activity. Global Choices relies on the following lawful bases to process Personal Data, as permitted under applicable law:

• Processing necessary for the negotiation, execution, or performance of contracts;
• Processing to comply with legal and regulatory obligations;
• Processing in furtherance of our legitimate interests, including our interests to conduct legitimate business activities (such as improving our products and services, to communicate with you, and to secure our systems, among other legitimate interests); and
• Processing based on your consent.

We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law (for example, in relation to our direct marketing activities and our use of cookies). If we ask for your consent to process your Personal Data, you may withdraw your consent at any time by contacting us using the details at the end of this Notice. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

Where required by law, we may obtain your explicit consent to collect and use special category data (see the end of section 2 above) about you. Other legal bases for our processing of special category data may include, as permitted by applicable law, for reasons of substantial public interest or as necessary for the establishment, exercise or defense of legal claims.

You can contact us (see the “contact Us” section below) for more information about our processing of your Personal Data.

4. Disclosures of Personal Data

Where required by applicable law, Global Choices does not rent, sell, or share Personal Data about you with non-affiliated persons for their direct marketing purposes unless we have your permission. Otherwise, however, we may disclose your Personal Data to the following categories of third parties without your consent as permitted by applicable law:

• Service Providers, which are entities that process Personal Data on behalf of Global Choices.
• Persons with legal rights to access Personal Data, including, as the case may be, law enforcement agencies, intelligence services, competent administrative and judicial authorities, and persons with validly issued subpoenas, warrants, or other forms of legal process;
• Parties involved in potential business transactions, including potential acquirers and other stakeholders in the event of a merger or legal restructuring operation such as an acquisition, joint venture, assignment, spin-off, divestiture, or bankruptcy; and
• Other Third Parties, as required or allowed by law.

We may also disclose your Personal Data to third parties such as social networking and other sites if you direct us to share your Personal Data with such sites or to other entities that do not fall in one of the above categories with your permission.

5. Cross-border Transfers of Personal Data

Global Choices operates globally and, consistent with applicable laws, may process your Personal Data in jurisdictions that are not regarded as providing the same level of protection to Personal Data as the jurisdiction in which you are based.

When transferring Personal Data across borders, we take steps to safeguard and protect such Personal Data as required by applicable laws. These safeguards may include:

• Transferring Personal Data to recipients located in countries deemed to provide an adequate level of protection for Personal Data including where Personal Data originates in the European Union, to countries which the European Commission has deemed to provide an adequate level of protection for Personal Data;
• Pursuant to your consent; and
• Entering into agreements containing contractual safeguards, such as the Standard Contractual Clauses that have been approved by the European Commission.

Please do not hesitate to contact us if you have any question concerning the transfer of your Personal Data (see the “Contact Us” section below).

6. Data Security and Retention

Global Choices implements various technical, administrative, physical, and organizational measures to protect the security and confidentiality of Personal Data. While we take measures to safeguard your Personal Data, we cannot guarantee that the Personal Data we process will remain secure.

Where required by law, Global Choices will retain Personal Data only for as long as necessary to accomplish the purposes for which the Personal Data was collected or for the period required by the applicable laws (whichever is longer).

To determine the appropriate retention period for your Personal Data, Global Choices considers the following factors:

• The volume, nature, and sensitivity of the Personal Data;
• The potential risk of harm from its unauthorized use or disclosure;
• The purposes for which we process it and whether we can achieve those purposes through other means; and
• Applicable legal requirements.

When the retention of your Personal Data is no longer necessary for the purposes for which it was collected or our retention of such Personal Data is no longer allowed or required by law, we will delete, anonymize, deidentify, or aggregate the Personal Data such that it is no longer associated with you.

7. Your Choices and Rights

Some jurisdictions have provided individuals with certain rights in relation to the processing of their Personal Data. These rights are not available to everyone, and they do not necessarily apply in all contexts. Depending on applicable law and the context of the request, you may have the rights to:

• Request access to or transfer of your Personal Data.
•  Request correction of your Personal Data (should your Personal Data be inaccurate, incomplete, or obsolete).
•  Request deletion of your Personal Data.
• Withdraw your consent to processing (where we processed Personal Data on the basis of your consent). Please note that withdrawing your consent applies only to future processing activities.
• Object to or request restrictions on the processing of your Personal Data.
• Opt-out of certain transfers to third parties.

To exercise a right that you believe you may be entitled to under applicable law, please contact us at [email protected] or as indicated below. We may need to verify your identity before we fulfil your request.

If you feel that we have failed to comply with your request or have not addressed a complaint that you have, please contact us.  You may also have the right to complaint to the competent data protection or other regulatory authority in your jurisdiction.

8. Children’s Data

We do not knowingly process Personal Data relating to individuals younger than 16 without the permission of the minor’s guardian, except where permitted under applicable law. If you have reason to believe that we are processing Personal Data relating to a minor without permission from the minor’s guardian, please notify us at [email protected].  

9. Revisions to this Notice

We may update this Notice from time to time. You are encouraged to consult this Notice on a regular basis and check the date on which the Notice was last updated, as shown at the beginning of the Notice. When we make a material change to the Notice, we may notify you by placing a notice on our website or notice as otherwise required by law.

10. Contact Us

To exercise your rights or make a request concerning the processing of your Personal Data, you may contact us by:

• Emailing us at [email protected];
• Mailing us at 245 Fox Run Drive, Carbondale, CO 81623, United States; or
• Calling us at +1 970.963.5646