Tent Partnership for Refugees’ Mentorship Program for Ukrainian Refugees in Poland

PRIVACY STATEMENT

This privacy statement (the “Privacy Statement”) sets out how the Tent Partnership for Refugees, 200 Lafayette Street, New York, New York, 10012, United States, (‘we’ or ‘us’ or ‘our’ or “Tent”) will use any information that you give to Tent or that we collect in the context of operating during the Mentorship Program for Ukrainian Refugees.

Tent is a non-profit organization launched in 2016 to mobilize the global business community to support refugees. Tent manages a network of over 200 major companies committed to integrating refugees in their host communities.

Tent is a globally focused organization that is headquartered in the United States. The Mentorship Program for Ukrainian Refugees in Poland will enable Tent to work with organisations and individuals in Poland. In very rare cases organisations and individual from multiple countries in Europe, including Germany, France, Italy, Netherlands, Sweden, Switzerland, UK and Spain. Because of this, we have drafted this Privacy Statement to ensure that any information we process complies with all relevant data protection laws in these countries. To see Tent’s global Privacy Policy, please see here: https://www.tent.org/privacy-policy/

Tent is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when collaborating with us, then you can be assured that it will only be used in accordance with this Privacy Statement.

Tent may change this statement from time to time and will let you know if we do so via email. This statement is effective from November 2022.

Tent complies with any applicable legislation relating to data protection or privacy of individuals in force from time to time in the European Union (“EU”), the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, including and without limitation: the Privacy and Electronic Communications (EC Directive) Regulations 2003, or any other legislation that implements any other current or future legal act of the EU, the UK or Switzerland concerning the protection and processing of personal data (including Regulation (EU) 2016/679 of the European Parliament and the Council (“GDPR”), as it forms part of the laws of (i) England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; and (ii) Switzerland, and any national implementing laws, as well as any applicable laws or regulations on cyber security (“the Data Protection Legislation”)) and any act or regulation which replaces, supplement or amend the above from time to time, whilst processing any personal data in relation to the Mentorship Program for Ukrainian Refugees.

The terms “data controller,” “data processor,” “data subject,” “personal data” and “processing” in this Privacy Statement shall be interpreted in accordance with the applicable Data Protection Legislation.

Please contact the Tent team at [email protected] with any questions arising out of this Privacy Statement.

Data controller and processors
Tent acts as data controller for all data processed for the Mentorship Program for Ukrainian Refugees. In simple terms, this means we (i) “control” the personal data that we collect from you or other sources; and (ii) make certain decisions on why and how we use and protect such personal data.

Who we share your personal data with
Tent may disclose personal data, where permitted by the Data Protection Legislation, to our service providers, professional advisors, persons employed and/or retained by them in order to fulfil the purposes of the Mentorship Program for Ukrainian Refugee.  For example, we use [Google, Microsoft Excel, Salesforce, Survey Monkey and Box] as third-party data processors for the purposes of secure storage and have appropriate contracts and procurement checks in place to ensure they both comply with our terms set as data controller as well as all relevant Data Protection Legislation.  Your information will be shared with your mentor or your mentee, the company where the mentor is employed, Tent and the NGO that referred the mentee for this mentorship program to fulfil the purpose of the Mentorship Program for Ukrainian Refugees as described under the section “What we do with your information” below.

What we ask you to submit and what information we process
In connection with the Mentorship Program for Ukrainian Refugees, we may collect, record, store, adapt, otherwise process, and use personal data of mentors and/or mentees.

What personal data do we collect from mentors and/or mentees and on what lawful basis?
As an individual in a mentor or mentee capacity, we may ask you to provide the following categories of personal data:

What we do with your information

Tent may process the personal data you submit for the following purposes related to the Mentorship Program for Ukrainian Refugees:

• Analyze the information to make sure that participants are a good fit for the Mentorship Program.
• Share the information with the companies and NGO implementing partners participating in this Mentorship Program for Ukrainian Refugees so that they can support matching mentors and mentees based on similar professional and personal interests. Note that each mentee’s data will only be shared with one company that they have been assigned to for mentorship.
• Invite participants to attend (training) webinars and events (e.g. workshops, hiring fairs) focused on the economic integration of refugees. Note that we may co-host these events with other NGO implementing organisations, companies and government agencies that are interested in supporting the economic integration of refugees.
• In cases where mentees are dealing with a difficult professional or personal situation or are being unresponsive to their mentor’s outreach, Tent or the company who is mentoring this mentee will reach out to the NGO that referred the mentee for this mentorship program for additional guidance or support.
• For legal and regulatory purposes, where we are complying with applicable laws and statutory requirements and/or responding to and complying with requests and legal demands from regulators or other authorities.
• Any further purpose not incompatible with the initial purposes, for which notice has been provided, or has been agreed to, in writing prior to any processing of your personal data for such processing taking place.

We are committed to ensuring that your information is secure. To prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Data Transfers
Tent is an international organization and, for the purposes listed under section “What we do with your information and the lawful basis” above, Tent may transfer your personal data outside of the European Economic Area to countries that do not ensure a similar level of personal data protection as in the European Economic Area, such as the United States. All mentees joining the Mentorship Program for Ukrainian Refugees have given their consent to share their personal data outside of the European Economic Area to Tent employees based in the United States  in order to support the administration of the Mentorship Program for Ukrainian Refugees. We may also transfer your personal data to the third-party service providers located outside the European Economic Area on the basis of appropriate or suitable safeguards in compliance with the Data Protection Legislation, including without limitation a valid adequacy decision from the European Commission (Article 45 GDPR) or the European Commission approved standard contractual clauses (Article 46 GDPR), as updated from time to time.

For information on the safeguards applied to such transfers of personal data outside of the UK and Europe, please contact the Tent team at [email protected]. You have a right to obtain a copy of the appropriate or suitable safeguards or such safeguards may be made available for you.

Data retention and access

We employ appropriate technical and organisational measures, including physical, electronic and procedural safeguards to protect personal data in their possession or under their control.

For information on the safeguards applied to the retention of personal data, please contact the Tent team at [email protected].

We will retain your personal data for so long as is necessary for you to participate in the Mentorship Program for Ukrainian Refugees. Thereafter, we will retain your name, contact details, info about your professional background and details of the relevant mentor and mentee match for a maximum of 3 years in order to contact you in regards to the Mentorship Alumni Program, and for longer periods of time where required or permitted by applicable laws to which Tent is subject.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Statement. You should exercise caution and look at the Privacy Statement applicable to the website in question.

Data subject rights
Subject to the applicable Data Protection Legislation, you have the following rights under the Data Protection Legislation in respect to your personal data:

• Access: You may request access to the personal data we have collected on you. We will respond to your request as soon as possible and (save for in certain circumstances) within one month;
• Correction: You may notify us to correct the personal data we hold about you, for instance, if you have changed your address or phone number;
• Deletion: You may also elect to have the personal data we have collected on you deleted from our customer database;
• Restricting Our Use: You may request that we stop processing your personal data (other than storing it), if: (i) you are verifying the accuracy of it; (ii) you believe the processing is against the law; (iii) you believe we no longer need your information for the purposes identified to you; or (iv) you are verifying whether our legitimate grounds to process your personal data, override your own rights;
• Transfer: If you wish to transfer (data portability) your personal data to another organization as a data controller (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means;
• Object to the Processing: You may object to the processing of your Personal Data (such as on grounds relating to your particular situation where such Processing is based on our legitimate interests or on public interest); and
• Right to Withdraw Consent: If you previously gave us your consent to process your personal data in for a particular purpose, you can contact us at [email protected] to let us know that you withdraw that consent at any time.

We do not carry out any automated processing, which may lead to an automated decision based on your personal data.

Changes and Updates
This Privacy Statement is valid from the date of update indicated below. However, Tent may subsequently update and/or integrate this Privacy Statement, also as consequence of possible subsequent amendments and/or integrations of the applicable laws. Changes will be notified in advance.

Our Contact Information
If you have any questions about this Privacy Statement or treatment of your personal data, data or if you want to execute one of your data subject right, you can contact the Tent team at [email protected].

If your query or complaint is not resolved by Tent to your satisfaction you have the right to make a formal complaint to the relevant national supervisory authority, with the competent data protection supervisory authority in the relevant jurisdiction where you live, work or where an alleged breach of the Data Protection Legislation has taken place. The list of all competent EU data protection supervisory authorities is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. In Poland, the Polish Data Protection Authority (Urząd Ochorny Danych Osobowych) is the competent authority with respect to data protection. You may contact the authority under the following address ul. Stawki 2, 00-193 Warszawa.

Publication Date: November 2022