Privacy Policy

The Children of Daniel (TCoD) — Privacy Policy

Effective date: 26/05/2025

Last updated: 30/09/2025

The Children of Daniel “TCoD” is committed to protecting the privacy and security of the personal information we collect about supporters, donors, volunteers, children and families we serve, employees, partners, website visitors, and other stakeholders. This Privacy Policy explains what personal information we collect, why we collect it, how we use and disclose it, how we protect it, and the rights available to individuals under national and international privacy laws (including, where applicable, the EU General Data Protection Regulation (“GDPR”), the UK Data Protection Act, the California Consumer Privacy Act (“CCPA”)/California Privacy Rights Act (“CPRA”), Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), and U.S. laws protecting children’s online privacy such as COPPA).

This Policy applies to personal information collected through our websites, mobile apps, donation pages, paper forms, events, and any other interactions with TCoD.

1. Controller / Contact Information

Controller: The Children of Daniel (TCoD)
Address: [Insert physical address]
General contact email: info@tcdaniel.org
Data Protection Officer (or privacy contact): (Divine Nnamdi, info@tcdaniel.org, 8003212005]

If you have questions, concerns, or requests about your personal information, please contact us at the email above.

2. What Personal Information We Collect

We collect personal information that is necessary to operate our programs and services and to communicate with you. Types of personal information include:

a. Identity & contact information — name, postal address, email address, phone number, date of birth (where required), emergency contact details.
b. Financial & transactional information — donation amounts, payment card or bank account details (collected by our payment processors), gift history, tax receipts, billing address.
c. Program beneficiary information — child’s name, age, gender, school, health or special needs information, family information, case notes, photos/videos (with consent), and progress/assessment records.
d. Volunteer & staff information — CV/resume, references, background checks, availability, timesheets.
e. Communications & engagement — correspondence, preferences, event registrations, survey responses.
f. Technical & usage data — IP address, device and browser information, pages viewed, cookies and similar tracking technologies, referral URLs, analytics data.
g. Sensitive data (where necessary and with explicit consent) — health information, special needs, and criminal history where required for safeguarding or compliance.

We do not knowingly collect personal information from children under the age of consent for your jurisdiction without parental/guardian consent. See Section 9 (Children’s Data).

3. Sources of Personal Information

We obtain personal information directly from individuals (e.g., donors, volunteers, beneficiaries, website users) and from third parties, such as:

  • Payment processors and fundraising platforms (Stripe, PayPal, etc.)
  • Background-check providers (for volunteer/staff screening)
  • Partner organizations, schools, local community groups, or sponsors
  • Publicly available sources (for due diligence)
  • Analytics and advertising providers (Google Analytics, Meta, etc.)

4. Purposes & Legal Bases for Processing

We process personal information to support our mission and operations. Examples include:

Primary purposes

  • To register beneficiaries, deliver education and welfare services, monitor progress, and maintain case files.
  • To process and acknowledge donations and issue receipts.
  • To recruit, manage, and communicate with volunteers and staff.
  • To manage partnerships, grants, and reporting obligations.
  • To provide news, updates, fundraising appeals, and event information (marketing and outreach).
  • To administer our website and improve services via analytics.

Legal bases (where applicable)

  • Contract: processing necessary to fulfill contracts (e.g., donation processing, volunteer agreements).
  • Legal obligation: where required by law (e.g., tax reporting, safeguarding).
  • Legitimate interests: for fundraising, program improvement, fraud prevention, and organizational administration (balanced with individuals’ rights).
  • Consent: for certain uses such as marketing emails, photos/videos of beneficiaries, or processing of sensitive data. You may withdraw consent at any time where processing is based on consent.

5. Sharing & Disclosure of Personal Information

We may share personal information with:

  • Service providers / processors who perform services on our behalf (payment processors, email platforms, cloud hosting, CRM providers, background-check vendors). We require contractual safeguards to protect personal data.
  • Partner organizations and schools for program delivery and beneficiary support.
  • Professional advisors, auditors and legal counsel to comply with legal requirements or protect our rights.
  • Granting agencies or funders when reporting on funded programs (only necessary information, usually aggregated).
  • Government authorities when required by law.
  • Public communications: We may publish beneficiary stories, photos, or videos for fundraising and transparency only with appropriate permission/consent. We will not publish identifying information about children without parental/guardian consent.
  • On sale or transfer: In the event of a reorganization, merger, or sale, personal data may be transferred subject to privacy safeguards and notice.

We never sell personal information for advertising purposes. If you are in California and are concerned about “sale,” please contact us (see Section 12).

6. International Transfers & Safeguards

TCoD operates internationally and may transfer personal information across borders (e.g., between our offices, processors, and partners). When transferring personal information outside your jurisdiction (for example, from the EU/UK/Canada to other countries), we will implement appropriate safeguards such as:

  • Standard Contractual Clauses (SCCs) or other legally recognized transfer mechanisms;
  • Binding corporate rules (where applicable);
  • Encryption, access controls, and contractual commitments from processors.

If you would like details on the safeguards in place for a particular transfer, please contact our DPO.

7. Data Retention

We retain personal information only as long as necessary for the purpose collected and to meet legal, accounting, and reporting obligations. Typical retention periods:

  • Donation and tax records: minimum 7 years (or longer if required by local law).
  • Beneficiary records and case files: retained for program duration + a defined archival period (varies by program and local regulations; typically several years).
  • Volunteer and staff records: employment/engagement duration + statutory retention periods.
  • Marketing data: until consent is withdrawn or opt-out is requested.

We securely delete or anonymize personal information once retention needs expire.

8. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to provide functionality, analytics, and marketing. Categories include:

  • Strictly necessary cookies – essential for basic website functions.
  • Performance/analytics cookies – to understand website usage (e.g., Google Analytics).
  • Functional cookies – to remember preferences and forms.
  • Advertising/marketing cookies – to deliver relevant content and measure campaigns.

You can manage cookie preferences via our cookie banner/settings or through your browser settings. Blocking some cookies may affect website functionality.

9. Children’s Personal Information & Safeguarding

Protecting children’s privacy is paramount. For any child under the legal age of consent in your jurisdiction:

  • We collect and process children’s personal information only to the extent necessary for program delivery, and only with documented parental/guardian consent (or other lawful basis such as a legal obligation).
  • We do not knowingly seek donations or direct marketing to children.
  • Photographs, videos or stories featuring children are only published with explicit permission from a parent or guardian; identifying details (full name, address, contact information) are excluded unless explicitly authorized.
  • We conduct safeguarding checks and background screening for staff and volunteers working with children.

If you believe a child’s personal information has been collected or published without proper consent, contact us immediately so we can investigate and remediate.

10. Security Measures

We maintain administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, alteration, or destruction. Measures include:

  • Access controls and role-based permissions.
  • Encryption in transit (TLS) and at rest where feasible.
  • Regular security assessments and audits.
  • Staff training on data protection and confidentiality.
  • Contractual security requirements for third-party providers.

No security system is perfect. In the event of a data breach affecting your personal information, we will follow legal obligations regarding notification to affected individuals and supervisory authorities.

11. Your Rights & Choices

Depending on your location and applicable law, you may have rights regarding your personal information. These may include the right to:

  • Access the personal information we hold about you.
  • Rectify inaccurate or incomplete data.
  • Erase (delete) your personal information (subject to retention obligations).
  • Restrict or object to processing (including for direct marketing).
  • Withdraw consent where processing is based on consent.
  • Data portability — receive your data in a common machine-readable format.
  • Right to opt-out of sale or sharing for targeted advertising (where applicable, e.g., under CCPA/CPRA).
  • Lodge a complaint with a supervisory authority (e.g., data protection authority in your country).

To exercise your rights, please contact our Divine at info@tcdaniel.org or use the contact details above. We may need to verify your identity before fulfilling certain requests. We will respond within the time periods required by applicable law.

12. Marketing Communications & Fundraising

We may use your contact information to send newsletters, fundraising appeals, and event invitations. You may opt-out of marketing communications at any time by:

  • Clicking the “unsubscribe” link in our emails; or
  • Contacting us at info@tcdaniel.org with “Unsubscribe” in the subject line.

For telephone or text message communications, you may opt out by replying “STOP” or contacting us directly.

13. Third-Party Links & Embedded Content

Our website may include links to third-party sites (partners, social media, payment providers). This Policy does not apply to external websites. We recommend reviewing the privacy policies of any third-party site you visit.

14. International Donors & Jurisdictional Notes

If you are an EU/EEA or UK resident, GDPR and UK Data Protection laws may provide additional protections and require that your data be processed lawfully. If you are a California resident, the CCPA/CPRA may provide particular rights (right to know, delete, opt-out of sale, and non-discrimination). For Canadian donors, PIPEDA governs certain commercial activities. Where there are variations in local law, we will comply with applicable legal requirements.

If you would like to know how the law in your jurisdiction applies to your personal information held by TCoD, please contact our us.

15. Data Protection Impact Assessments (DPIAs) & Risk Management

For higher-risk processing (e.g., sensitive beneficiary information, large-scale profiling, or cross-border data transfers), TCoD will carry out DPIAs and implement mitigation measures in line with legal obligations.

16. Complaints & Supervisory Authorities

If you are not satisfied with our response to a privacy request, you can lodge a complaint with the relevant supervisory authority in your jurisdiction (e.g., Information Commissioner’s Office (UK), Data Protection Commission (Ireland), European Data Protection Board (EU), California Privacy Protection Agency (CPPA), Office of the Privacy Commissioner of Canada).

17. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our operations or legal requirements. We will post the revised policy on our website with an updated effective date. Where required by law, we will notify you of material changes.

18. A Note on Legal Advice

This Privacy Policy is intended to be a clear and practical statement of TCoD’s privacy practices. It is not legal advice. For legal certainty, or to ensure compliance with specific national laws or funder requirements, please seek independent legal counsel. If you would like, we can provide suggested legal language for particular jurisdictions.

Acknowledgement & Consent
By interacting with TCoD (visiting our website, donating, volunteering, or participating in programs), you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of personal information as described (where consent is the legal basis).