The Population Council and its affiliates (collectively referred to as “we”, “us”, and “the Council”) are committed to being transparent and fair when we collect and use your personal information and to complying with the data protection laws that apply in the countries where we operate. Should you have any questions about this Notice, please let us know by contacting us at the email or addresses listed below in the section titled, “How to contact us.”

When does this notice apply?

This Privacy Notice applies to all personal data that the Council processes during the execution of its business activities, including data related to your use of this website. The Council has adopted the principles and requirements of the European Union’s General Data Protection Regulation (GDPR) as the basis for its privacy practices.

Third-party websites

Unless stated otherwise, this Notice does not apply to any third-party sites that may link to, or be accessible from, our websites. A link does not constitute endorsement of the content, viewpoints, accuracy, opinions, policies, products, services, or accessibility of that website. If you choose to follow a link to another website, you are subject to the terms and conditions of that website, including its privacy policy.

What personal data do we collect?

We collect only the personal data needed to advance our mission. For example, we collect personal data of study subjects as disclosed in informed consents when we are the sponsor of clinical trials or social and behavioral science research studies, and we collect personal data of donors in support of our fundraising activities. We also collect personal data of candidates, employees, and people with whom we work to the extent that it is needed to carry out standard business activities such as hiring and employing individuals or administering grants and contracts. We are committed to limiting personal data collection to what is necessary for a particular purpose.

Information You Provide

We collect certain personal data when you voluntarily provide it, either directly to us or via third-party vendors with whom we work to provide our services. The type of personal data we collect from you depends on how you interact with us. You can choose not to provide personal data when asked for it, but it may restrict our ability to provide you with some services you have requested. Examples of personal information you may provide include:

• Contact information and areas of interest if you donate to us or choose to receive newsletters, updates, or other information from us
• Personal or health information if you participate in a research study or a clinical trial with us
• Personal, educational and professional information if you apply for a position with us
• Personal data you include if you email, text, or instant message us, or contact us through forms on our sites
• Personal data contained in any proposal documents, feedback, comments, photos, videos, or other information you provide to us in the course of our business activities

Donor information

Personal data of donors is provided to us directly by donors or via third-parties that collect or process donations. This personal data includes name and contact information, amounts and dates of donations, subscription interests, and in some circumstances also includes honor or memoriam information, employer information, familial relationship information, and/or publicly available wealth information collected by us. If you choose to make donations through third-party donation processors, please be sure to review any linked policies provided during payment processing as they will apply to you. The Council does not store any donor credit card information. Except for vendors that we work with to process and manage donations and data, and which are bound by strict confidentiality obligations, we do not share donor information with third parties. The Council does not sell donor data.

Information collected through this website

Like most website operators, we collect information that web browsers and servers typically make available, such as the browser type, language preference, referring site and the date and time of each visitor request. The Council’s purpose in collecting this non-personally identifying information is to better understand how our visitors use the website, so we can improve the experience for everyone.

Website cookies

A cookie, and similar technology such as a pixel, is a small text file that a website stores on your computer. A cookie can capture information about your browser and browser activity, such as device and browser information, IP address, general geographic location, access time and date, and previously visited websites. You can find information about cookies at www.aboutcookies.org.

We use certain strictly necessary cookies to make our websites work. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. We use functional cookies to enable functions such as sharing content. We also use analytics and performance cookies to help understand how visitors are using our website and how the website is performing, in order to improve the website experience. Finally, we may use third-party advertising and marketing cookies that provide visitors with customized advertising based on their web-browsing history and to analyze effectiveness of ad campaigns.

Cookies can be managed or blocked through your browser. However, if your browser is set to block cookies, you may have some trouble accessing certain parts or functionalities on our sites. If the site has a “Manage Cookies” button, you can view, change and manage your cookie settings at any time. If the site does not have a “Manage Cookies” button, and you have not set your browser to block cookies, then your continued use of the site represents your consent to cookies and similar technologies.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

Click-through URLs

If you subscribe to our newsletters, our emails may use a “click-through URL” linked to content on our sites. When you click one of these URLs, they pass through a separate web server before arriving at the destination page on our sites. We use this click-through data to help us understand how recipients respond to, or interact with, our emails.

Social media and video sites

If you choose to share our content through social media networks like Facebook, Twitter and LinkedIn or watch one of our videos on a media site like YouTube, those third-party sites may place cookies on your computer. We do not control these cookies. Please check those sites for information about their use of cookies and how to manage them.

How do we use or process personal data?

The Council may process personal data:

• To undertake email actions
• To send you newsletters, if you choose to subscribe
• To ask you to donate or get involved in our campaigns
• To process donations that we receive from you
• To administer your application for employment
• To improve our website
• To conduct budgeting and financial audits
• To establish contractual or other business engagements
• To conduct scientific research studies
• To develop safety reports for clinical trials and products
• To conduct and share statistical analyses of scientific research data
• To contribute to our archive of information in the public interest
• To fulfill any legal obligations or to comply with the law
  

What is the basis for processing personal data?

Depending on the type of data provided, we may process your personal data based on:

Your consent. We may process your personal data for a specific purpose after obtaining your consent. Where we are relying on consent as the legal basis, we will notify you and seek additional consent before using your personal data for any purpose different from the original purpose. Although there are some exceptions, you have the right to withdraw your consent at any time, by contacting us at the email or addresses listed below in the section titled, “How to contact us.”

Legitimate interest. We may process your personal data to fulfill our legitimate interest in achieving our mission.

To fulfill a contractual obligation. If you engage with us, we will process the personal data you provide solely for the execution of the business activities associated with the engagement.

Legal obligation. The Council may disclose personal information in response to subpoenas, court orders or other legal process, to establish, exercise or defend our legal rights and to process a data subject’s request.

Is your personal data shared?

We may share your personal data with our employees, contractors and agents, as well as with third-party vendors and service providers, only as needed for the purposes listed in this Notice. If we share your personal data with third parties as described, we require that they comply with applicable data protection laws. We may share information with your consent or at your direction, such as when you choose to share information on our websites. We do not sell personal data to any third-party for marketing purposes.

Where is your personal data stored or transferred?

Your personal data may be stored, processed, or transferred in and to any other country where we or our service providers have facilities. We take appropriate steps to ensure that your legal rights and protections travel with any such transfer of your personal data as required by applicable law. When necessary under applicable law, we ensure appropriate safeguards for protecting your personal data are in place.

How long will your personal data be stored for?

We hold your personal data in our systems only for as long as necessary for the purposes listed in this Notice. We remove personal data from our systems once it is no longer required, in line with our guidelines on how long important information must remain accessible for future use or reference. The length of time each category of data will be retained will vary depending on the length of time required to process it, the reason it was collected, and to comply with any statutory requirements. After this time, the data will either be deleted or we may retain a secure anonymized record for research and analytical purposes.

What data privacy rights do you have?

Under GDPR, you have the right, subject to applicable local data protection legislation, to:

• Withdraw your consent, when the collection and use of your personal data was based solely on your consent
• Request access to, and receive a copy of the personal data we hold
• Request correction or erasure of the personal data that are inaccurate
• Request the deletion of personal data in certain circumstances, such as withdrawal of consent or when the data is no longer necessary for the purpose for which it was collected or processed
• Restrict processing of personal data where the accuracy of the personal data is contested, the processing is unlawful, or if the data subjects have objected to the processing
• Receive or have transferred to another processor the personal data in structured, commonly used and machine-readable format
• Object to processing for direct marketing, or to processing for scientific/historical research/statistical purposes
  
  

Even if you object to the processing of personal data, we are nevertheless allowed to continue the same if the processing is (i) legally mandatory, (ii) necessary for the performance of a contract to which you are a party, (iii) necessary for the performance of a task carried out in the public interest, or (iv) necessary for the purposes of the legitimate interests we follow, including the establishment, exercise or defense of legal claims.

Under South Africa’s Protection of Personal Information Act (POPIA), you have the right to have your personal information processed in accordance with the conditions for the lawful processing of personal information, including the right-

• To be notified that—
  • personal information about you is being collected; or
  • personal information has been accessed or acquired by an unauthorized person
• To establish whether your personal information has been collected and to request access to your personal information
• To request, where necessary, the correction, destruction or deletion of your personal information
• To object, on reasonable grounds relating to your particular situation, to the processing of your personal information
• To object to the processing of your personal information for purposes of direct marketing
• Not to have your personal information processed for purposes of direct marketing by means of unsolicited electronic communications except where consent was given;
• Not to be subject, under certain circumstances, to a decision that is based solely on the basis of the automated processing of your personal information for profiling purposes
• To submit a complaint to the Regulator regarding the alleged interference with the protection of the personal information of any data subject or to submit a complaint to the Regulator in respect of a determination of an adjudicator
• To institute civil proceedings regarding the alleged interference with the protection of your personal information
  
  

Subject to the limitations set forth herein and/or in applicable local data protection laws, you can exercise the above rights by contacting the Council.

How to contact us

Please direct all data privacy requests and inquiries to: datarequests@popcouncil.org. Please be sure to provide the following information when contacting us: First & Last Name/ Business Name, and Email Address.

If you prefer to contact us by mail:

The Population Council

Attn: Legal – Privacy Notice Request

One Dag Hammarskjold Plaza

New York, New York 10012

If you reside in South Africa:

IPM South Africa NPC

Attn: Information Officer

Woodlands Office Park

Building 16, First Floor

20 Woodlands Drive

Woodmead

Johannesburg 2191

South Africa

On receiving your communication, we are likely to request evidence of your identity to ensure your personal data and information connected with it is not provided to anyone other than you.

Effective date

The effective date of this page is September 28, 2023. The Council reserves the right to amend this policy from time to time at its sole discretion. We encourage visitors to frequently check this page for any changes to the Privacy Notice. Your continued use of our services and of this site after any change in this Privacy Notice will constitute your acceptance of such changes.