Privacy Policy

Last Updated: May 24, 2018

1. WHO ARE WE?

This website (“Site”) is operated by Menstrual Health Hub (“MH Hub”, “we”, “us” and/or “our”), a global organization that establishes strategic partnerships to promote collaborative, systemic change around menstrual health worldwide., a fiscally-sponsored charitable project of the Institute for Education, Research and Scholarhsips registered in the United States with EIN registration number 72-1585854. Our registered address is 800 Wilshire Boulevard, Suite 200, Los Angeles, California 90017, USA. You can contact us as indicated under the “Contact” section in the main navigation.

The data controller responsible for your personal data is MH Hub with whom you contract as a customer, member or membership applicant (“MH Hub”, “we”, “us” and/or “our”).

2. WHAT IS THIS PRIVACY POLICY IS FOR?

This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this Site or as a partner, registered organization, Founding Circle member, subscriber, or customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which will become applicable to us and you as of 25 May 2018.

‘Personal data’ as used in this Privacy Policy means any information that relates to you from which you can be identified.

By using our Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

3. PERSONAL DATA WE COLLECT

We collect the following personal data about you:

  • MH Hub Global Menstrual Health Registry: The personal details you provide when filling out the “MH Hub Global Menstrual Health Registry” include the name of your organization, the website address, a one-liner about your organization, the ‘PAVING PATHWAY’ that best describes your approach to menstrual health, the best contact for your organization (name and email), a detailed description of what your organization does, your organzation’s PRIMARY focus on menstrual health, information about your menstrual health program(s), your collaborations, your regional focus, the countries you work in, the address of your headquarters, the target audience of your work, and your input for what will help strengthen your work around menstrual health. We also ask if there is anything else you want to share with the MH Hub.
  • Newsletter Subscription: When opting in to subscribe to our email newsletter, the ‘Menstrual Memo’, we collect your email address, and in some cases your first and last name, company and geographic location.
  • Other Information: Personal details you choose to give when corresponding with us by phone, video conference or e-mail, participating in user/customer surveys or otherwise visiting and interacting with this Site or any other websites we operate, and personal data that you provide to us when you visit one of our flagship conferences or other premises.

4. AUTOMATICALLY COLLECTED PERSONAL DATA

  • Log Data: When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.
  • Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features.

5. HOW WE USE YOUR PERSONAL DATA

We use your personal data in the following ways:

  • To acknowledge and confirm your registration to the “MH Hub Global Menstrual Health Registry”. Such use of your data is necessary in order for internal members of our team to review the registration.
  • To contact you in connection with partner, registered organization, Founding Circle member, subscriber, or customer surveys and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.
  • If you choose to subscribe (opt-in) to one our newsletter, the “Menstrual Memo”, we will send our periodic newsletter to the email address you provided us. Members can opt-out of our newsletters at any time by clicking the “Unsubscribe” link that is present on every email at the very bottom of the newsletter.
  • We may use your personal data for other purposes which you have consented to at the time of providing your data.
  • As necessary for certain legitimate business interests, which include the following:
      • to administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.
      • to conduct analytics to inform our marketing strategy and enable us to enhance and personalize the experience we offer to our members and our communications, including by creating customer or member profiles to enable personalized direct marketing communications.
      • if you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
      • we may anonymize, aggregate and de-identify the data that we collect and use such anonymized, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to better understand the richness and diversity of the menstrual health community working around the world.
      • for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure.
      • to (a) comply with legal obligations, (b) respond to requests from competent authorities; enforce our Terms of Use; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforcing or defending legal rights, or preventing damage.

As used in this Privacy Policy, “legitimate interests” means the interests of the MH Hub in conducting and managing our organization. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).

6. DISCLOSURE OF YOUR INFORMATION

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

  • MH Hub-Affiliated Businesses: We operate on a global scale. In order to provide the services you request from us, we may provide our affiliated businesses or consulting clients with information we collect from you for the purposes described above. Our affiliated businesses will only use your data for the purposes for which we originally collected it, which is to increase the collective impact of menstrual health worldwide.
  • Business Transfers: if we sell our business or our company assets are acquired by a third party personal data held by us about our applicants, members, customers may be one of the transferred assets.
  • Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms of Use or other applicable contract terms that you are subject to or (iii) to protect us, our members, applicants, customers, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organizations.

7. PAYMENT INFORMATION

Any credit/debit card payments and other payments you make through our Site will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.

We may arrange that card or payment data you submit in support of a member or customer transaction fee is stored for the purpose of processing your member or customer transaction fees.

You may choose to opt out of our third party payment providers holding your card or payment data although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee or for the purpose of making any future purchases.

8. SECURITY

Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or log-in details with anyone else.

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organizational security measures to protect the personal data that you submit to us against unauthorized/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

9. PERSONAL DATA RETENTION

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain membership records for six years after expiration or termination of your membership. We retain information submitted through the Site and the other websites we operate for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means.

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

10. YOUR PERSONAL DATA PROTECTION RIGHTS

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:

  • Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a digital copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional print copies, we may need to charge a reasonable fee.
  • Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your personal data, and we will do so:
    • If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing or
    • If we are processing your personal data for direct marketing.
  • Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the UK data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorized to hear those concerns (you may find EU Data Protection Authorities’ contact information here.)

If you wish to exercise any of these rights please contact us as described in the “Contact” section below. We may also need to ask you for further information to verify your identity before we can respond to any request.

11. DELETING REGISTRATION DETAILS

If you would like to delete your Global MH Hub Menstrual Health Registry registration, please send us an email to info@mhhub.org. Please let us know your organization’s name in that email, so that we may complete your request accurately.

In addition, we have the right to delete any account at any time if required to do so by process of law, or if necessary in order to investigate fraud, a violation of our Terms of Use or in connection with any harm being caused to a third party or their rights.

12. CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to info@mhhub.org.

13. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.