Privacy Policy – Data Protection Notice

Identity and Contact Details of the Data Controller

GREENLAMP, a charitable association registered in the Registry of Commerce of the Canton of Zurich, under reference
CHE-378.261.338

with registered office at:

c/o Haussmann Treuhand AG
Seefeldstrasse 45
8008 Zurich
Switzerland

The data controller for personal data within the meaning of the Swiss Federal Act on Data Protection (FADP) is GREENLAMP.

Contact for data protection inquiries:

privacy@greenlamp.ch

Personal Data Collected and Processing Purposes

In accordance with FADP, we inform you of the categories of personal data we collect and the purposes for which we process them.

2.1 Donor and Member Data (including residents of the European Union)

Categories of data collected:

Identity: surname, first name
Contact details: postal address, email address
Financial data: bank transfer details (account number, amount, date), tax status
Connection data: IP address, browser type, Internet Service Provider (ISP), visit timestamps
For members meetings: photos, food preferences and such like

Processing purposes:

Issuing and sending donation receipts (tax and accounting obligations)
Communicating information about the progress of projects supported by GreenLamp
Production and distribution of periodic newsletters and reports
Sending invitations to fundraising, statutory meetings and information events
Statistical analysis of website visit trends
Website administration and optimisation

Legal basis: Legitimate interest: informing donors about the appropriate use of their contributions and maintaining relationships with our supporters. Legal obligation for tax receipts and for statutory meetings.

2.2 Beneficiary Data (mainly in Ethiopia)

Categories of data collected:

Identity: surname, first name, date of birth
General family circumstances (non-sensitive information necessary to create a link between the beneficiary, their sponsors and/or local partners)
Academic progress (for reports to donors)
Images

Processing purposes:

Establishing a personal connection between sponsored students at the Ethiopian Partner Midwifery Colleges and sponsors
Providing progress reports to donors on the use of their contributions
Social media communication
Administrative management of sponsorship programs
Monitoring of the evolution of personal situation of the beneficiaries

Legal basis: Legitimate interest: enabling donors to track the concrete impact of their donations, helping beneficiaries in the field of health, education, social and personal development, raising awareness of GreenLamp and fundraising.

2.3 Website Visitor Data

Categories of data collected:

Connection logs: IP address, browser type, ISP, timestamp, pages visited, number of clicks
Cookies and browsing preferences

Processing purposes:

Analysis of traffic trends
Website administration
User experience optimisation
Content personalisation based on preferences

Legal basis: Legitimate interest: continuous improvement of our online services.

2.4 Partners

Categories of data collected:

Identity: surname, first name, date of birth, address
Contact details: phone number, e-mail address, role and/or function
Images
Financial data

Processing purposes:

Establishing a personal connection between sponsored students at the Ethiopian Partner Midwifery Colleges and their sponsors
Providing progress reports
Social media communication
Administrative management of sponsorship programs
Monitoring of the evolution of personal situation of the beneficiaries
Financial data to process invoice payments

Legal basis: Legitimate interest

2.5 General Principles

GreenLamp does not purchase or sell personal data
GreenLamp does not collect data from public sources (telephone directories, electoral registers)
GreenLamp does not use automated profiling or automated decision-making
Data is collected from the concerned individual, via websites (for donation purposes), via our staff members, via our volunteers and/or via our partners (individuals and organisations)
GreenLamp processes sensitive data within the meaning of FADP (health data, and/or race, etc.) in order to assess whether our beneficiaries meet our criteria, to facilitate the organisation of events and/or to provide information to concerned parties.

Recipients and Data Communication

In accordance with FADP, we inform you of the recipients or categories of recipients to whom your personal data may be transmitted.

3.1 Internal Communication

Personal data is accessible only within GreenLamp by:

Members of the Board, as well as staff members
Volunteers
Persons specifically authorised by the data controller for defined tasks relevant to GreenLamp ‘s objectives

Minimisation principle: Access is strictly limited to persons who need to know the data to perform their functions.

3.2 External Communication

GreenLamp does not share your personal data with other organisations, except in the following cases:

Ethiopian partners:

Data of sponsored students communicated to Ethiopian Partner Midwifery Colleges and partner institutions in Ethiopia
This communication is part of our statutory mission and is done with the prior consent of the beneficiaries or their legal representatives if and where needed
Appropriate contractual safeguards are in place (see section 4)

Technical service providers:

Website host (based in Switzerland or the European Union)
Web analytics services – with opt-out option
IT solutions used by GreenLamp to provide its services

GreenLamp does not sell or rent your data to commercial mailing lists.

International Transfers of Personal Data

In accordance with FADP, we inform you of transfers of personal data to foreign countries.

4.1 Transfers to the European Union

Some data may be hosted or processed in European Union countries. Switzerland has recognised that the level of data protection in the EU is adequate.

4.2 Transfers to Ethiopia

As part of our charitable mission, we transfer personal data concerning sponsored students to our chosen partners in Ethiopia (particularly the Ethiopian Partner Midwifery Colleges).

Ethiopia does not have data protection legislation recognised as adequate by the Federal Council.

Safeguards may include:

Standard contractual clauses approved by the Federal Data Privacy and Information Commissioner

Contractual commitment of partners to respect data protection principles equivalent to those of the Federal Act on Data Protection
Strict limitation of transferred data to what is strictly necessary for the accomplishment of our mission
Technical and organisational security measures based on Memorandum Of Understanding/collaboration agreements

4.3 Transfers to the United States

Our website uses cookies that may result in data transfers to the United States.

Opt-out option: You can refuse the use of cookies on our website directly

4.4 Other transfers

We may also transfer personal data to other countries, in particular where websites (related to donations) are hosted, as well as to cloud providers.

In general, GreenLamp monitors its providers on a regular basis, notably for those located outside of Switzerland. We consider equivalent jurisdictions according to the annex of the Swiss Ordinance on Data Privacy.

Data Retention Period and Security

5.1 Retention Period

In accordance with the principle of storage limitation, we retain your personal data only for the period necessary for the purposes for which they are collected.

Applicable retention periods (starting at the end of the financial year unless mentioned):

Data category	Retention period
Donor data (taxation)	10 years (accounting and tax obligations)
Beneficiary data	Duration of sponsorship program + 3 years
Connection logs	12 months maximum
Cookies	According to defined duration (see section 7)

Deletion: Beyond these periods, data is securely deleted or anonymised, unless a legal obligation requires longer retention.

5.2 Data Security

GreenLamp implements appropriate technical and organisational measures to protect your data against loss, unauthorised access, disclosure, modification, or destruction.

Security measures:

Privacy by Design and Privacy by Default: Data protection integrated from the design phase of processing operations
Access control: Access to data strictly limited to authorised persons
Strong authentication: Robust passwords
Regular backups: Secure backups to prevent data loss
Training: Regular awareness-raising of Board members, staff and selected volunteers on data protection issues

5.3 Data Breach Notification

In the event of a security breach assessed as likely to result in a high risk to your rights and freedoms, GreenLamp commits to:

Notify the Federal Data Privacy and Information Commissioner as quickly as possible (within 72 hours) of discovering the breach
Inform you directly if the breach is likely to seriously affect your personal or fundamental rights; this information is shared as soon as possible.

Rights of Data Subjects

The Federal Act on Data Protection grants you several rights that you can exercise free of charge.

6.1 Right of Access

You have the right to know whether personal data concerning you is being processed and to obtain:

A copy of your personal data
Information on the purposes of processing
The retention period
Recipients or categories of recipients
The origin of the data if it was not collected directly from you

6.2 Right to Rectification

You have the right to request the correction of inaccurate or incomplete personal data concerning you.

6.3 Right to Object

You may object at any time to the processing of your personal data based on our legitimate interest, for reasons relating to your particular situation.

6.4 Right to Erasure

You may request the deletion of your personal data when:

It is no longer necessary for the purposes for which it was collected
The processing is unlawful
You have objected to the processing and there is no overriding legitimate reason

Limitations: This right does not apply if we must retain your data to comply with a legal obligation (for example, accounting retention).

6.5 How to Exercise Your Rights

To exercise any of these rights, please send your request by email/mail to addresses indicated under section 1.
Response time: We commit to responding to you within 30 days of receiving your request.

Free of charge: Exercising your rights is free. No fees will be charged for an access request or any other request.

Identity verification: For security reasons, we will verify your identity before acting on your request.

6.6 Right to Lodge a Complaint

If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC):

Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
3003 Bern
Switzerland
Email: info@edoeb.admin.ch
Website: https://www.edoeb.admin.ch

Cookies and Tracking Technologies

Our website https://Greenlamp.ch uses cookies and similar technologies to improve your browsing experience.

7.1 What is a Cookie?

A cookie is a small text file stored on your device (computer, smartphone, tablet) when you visit a website. Cookies allow the site to recognise your device and remember certain information about your preferences.

7.2 Types of Cookies Used

Strictly necessary cookies:
These cookies are essential to the functioning of the website. They enable basic navigation and access to secure areas. These cookies do not collect personally identifiable information.

Analytical cookies:
We use Google Analytics to analyse traffic to our website. These cookies collect anonymous information about how visitors use our site (pages visited, time spent, traffic source). This information helps us improve the operation of our site.

Advertising cookies:
Google uses DART cookies to deliver targeted adverts based on your browsing history on our site and other websites.

7.3 Cookie Management and Opt-Out

Opt-out of Google DART cookies:
You can refuse the use of DART cookies by visiting Google’s privacy policy page:
https://policies.google.com/technologies/ads

Browser settings:
You can configure your browser to refuse all cookies or to be notified when a cookie is set. Consult your browser’s help section for more information:

Warning: Blocking certain cookies may affect the user experience and may affect the functioning of our website.

7.4 Cookie Retention Period

Session cookies: Automatically deleted when you close your browser
Other cookies: Retention is based on the process implemented by the corporations mentioned in this section 7.

Links to External Websites

Our website may contain links to external websites operated by third parties. GreenLamp is not responsible for the content of these sites or their data protection practices.

Once you leave our site via an external link, you are subject to the privacy policy of the third-party site, not that of GreenLamp.

We recommend that you consult the privacy policy of each website you visit.

The links to external websites as indicated in the current data privacy notice are given without any guarantee from GreenLamp and are for illustrative purposes only.

Register of Processing Activities

In accordance with Federal Act on Data Protection, GreenLamp maintains an internal register of its personal data processing activities.

This register contains in particular:

The identity of the data controller
The purposes of processing
The categories of data subjects and data processed
The categories of recipients
Retention periods
Security measures

Note: GreenLamp, as a private person, is not required to communicate this register to the Federal Data Privacy and Information Commissioner.

Modifications to this Notice

GreenLamp reserves the right to modify this Data Protection Notice at any time, particularly to comply with any regulatory, jurisprudential, editorial, or technical developments.

We invite you to consult this page regularly to become aware of any modifications.

The most recent version of this Notice is always available on our website: https://Greenlamp.ch

Contact

For any questions regarding this Data Protection Notice or to exercise your rights, you can contact us by using the contact details mentioned in section 1.

Consent and Acceptance

By providing us with your personal data, you acknowledge that you have read this Data Protection Notice and accept the processing methods described therein.

For minors under 16 years old: If you are under 16 years old, you must obtain the consent of your parents or legal representative before providing GreenLamp with your personal data.

GreenLamp is committed to respecting your privacy and protecting your personal data in accordance with applicable Swiss legislation.