Effective Date: November 21, 2024

Tributary Initiative for Learning (TRIL) is committed to protecting the privacy and personal information of its supporters, beneficiaries, volunteers, and website users. This Privacy Policy outlines our practices concerning the collection, use, and protection of personal data in compliance with applicable data protection regulations, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and other relevant laws.

By using our website or interacting with us, you agree to the practices described in this policy.

1. Who We Are

Tributary Initiative for Learning (TRIL) is a non-profit organization based in Lagos, Nigeria, dedicated to advancing education and learning opportunities. For data protection purposes:

• Data Controller: Tributary Initiative for Learning (TRIL)
• Contact Email: privacy@trilearning.org
• Website: https://trilearning.org

2. What Data We Collect

We collect and process personal data to provide our services, engage with supporters, and improve our offerings. The types of personal data we collect include:

2.1. Personal Data

• Contact Information: Name, email address, phone number, and postal address.
• Professional Information: Organization name, job title, and related details if provided.
• Communication Data: Information shared when contacting us or subscribing to updates.

2.2. Usage Data

• IP address, browser type, operating system, referring URLs, and details about your interactions with our website (e.g., pages visited and time spent).

2.3. Sensitive Information

We do not intentionally collect sensitive information (e.g., racial or ethnic origin, political opinions, religious beliefs). If you provide such data voluntarily (e.g., in a form or communication), we will process it only for the specific purpose for which it was provided.

3. How We Use Your Data

We process personal data based on the following lawful grounds:

• Consent: When you opt-in to receive newsletters or updates.
• Contractual Obligations: To provide services or respond to inquiries.
• Legal Obligations: To comply with legal or regulatory requirements.
• Legitimate Interests: For operational purposes, such as improving our website or ensuring its security.

Specific Uses Include:

1. Providing, maintaining, and improving our services and website.
2. Managing event registrations and communications.
3. Sending newsletters, updates, and fundraising appeals (with opt-out options).
4. Analyzing website performance and user trends.
5. Ensuring compliance with applicable laws and regulations.

4. Your Rights

Depending on your location and applicable laws, you may have the following rights regarding your personal data:

4.1. GDPR Rights (EU/EEA Residents)

• Access: Obtain a copy of your personal data.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of your data (right to be forgotten).
• Restriction: Limit the processing of your data under certain conditions.
• Portability: Receive your data in a machine-readable format for transfer.
• Objection: Object to processing based on legitimate interests.
• Withdraw Consent: At any time, without affecting prior lawful processing.

4.2. CCPA/CPRA Rights (California Residents)

• Know: Request details about the categories and specific pieces of personal data we collect.
• Delete: Request deletion of your personal data (with exceptions).
• Opt-Out: Decline the sale or sharing of personal data (note: TRIL does not sell personal data).
• Non-Discrimination: Exercise your rights without facing discrimination.

4.3. How to Exercise Your Rights

To exercise any of your rights, please contact us at [Insert email address]. We will respond within the legally required timeframe.

5. Data Sharing and Disclosure

We may share your personal data with third parties in the following circumstances:

1. Service Providers: To facilitate website hosting, email distribution, or analytics.
2. Legal Obligations: To comply with applicable laws or respond to lawful requests.
3. With Your Consent: When you authorize specific sharing.
4. Nonprofit Reporting: As required by grant agreements or donor reporting obligations (in aggregated or anonymized form).

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by law. Afterwards, your data will be securely deleted or anonymized.

7. Data Security

We implement industry-standard security measures to protect your data. However, no method of transmission or storage is completely secure. If you suspect a data breach, please contact us immediately at [Insert email address].

8. International Data Transfers

As a global organization, your data may be stored or processed outside your country of residence. When transferring data internationally, we ensure adequate safeguards, such as:

• EU Standard Contractual Clauses (SCCs) for GDPR compliance.
• Similar mechanisms under applicable laws.

9. Cookies and Tracking Technologies

We use cookies to enhance your experience. For details about our use of cookies and how to manage them, visit our Cookie Policy [link to detailed policy].

10. Children’s Privacy

We do not knowingly collect data from children under 13 (or relevant age thresholds under local laws). If you believe we have collected data from a child, please contact us to address the issue promptly.

11. Updates to This Privacy Policy

We may update this policy periodically. Any significant changes will be communicated through our website or email. Please check this page regularly for updates.

12. Contact Us

If you have questions or concerns about this Privacy Policy, please contact:

Tributary Initiative for Learning (TRIL)
Email: privacy@trilearning.org
Website: https://trilearning.org