3. Collection and use of personal data

3.1 Personal data we collect and use

3.1.1
Personal data is information about you through which you can be identified (including where you can be identified by combining the data with other information).

3.1.2
21Hundred collects personal data about you either directly, (e.g. when you contact us, subscribe to our newsletter, respond to our calls, or are accepted into the programme), or indirectly from information generated about you in the course of our relationship with you (e.g., data collected from cookies and other similar technologies, which is described in our cookie notice here) and information we collect about you from other sources, such as public databases (where permitted by law).

3.1.3
Personal data is not stored nor captured through the Website without your prior knowledge and consent. Where personal information is captured (e.g. through web-based forms for feedback, registration, requests, etc), the User will be informed as to what personal information is being collected, who will use it, and for what purpose(s) it will be used.

3.1.4
Personal data we collect directly from you may include the following:

• Personal details (e.g., first and last name, date of birth)

• Contact details (e.g., phone number, email address, city & country of residence, mailing address)

• Identification numbers (e.g., passport or ID details)

• Photographs for use in identification

• Your emergency contact details (e.g., names of your emergency contacts and their contact information)

• Banking details (e.g., when need to make payments or reimburse you)

• Health- and safety-related information we collect (e.g., so that we can make reasonable adjustments to improve the experiences we are able to offer you and to look after your wellbeing)

• Communications (e.g., when you contact us with questions, comments, or requests; when you participate in an event or respond to a survey)

3.1.5
Personal data we collect automatically about you

3.1.6
Any personal data that you give us will be treated with the utmost care and security. We will hold your data on our systems for as long as it is still used for the purpose stated when originally requested.

3.1.7
Should we use third-party platforms and applications that collect and use your data that we do not control, kindly refer to these third parties’ own privacy notices.

3.2 How we use your personal data and the basis on which we use it

3.2.1
We use the data you provide to use to facilitate your access to 21Hundred’s offerings, including the Fellowship Experience, Moya magazine, events and our newsletter.

3.2.2
This may include designing and improving offerings, making financial and logistical arrangements related to your experience of 21Hundred’s offerings and events, ensuring compliance with legal obligations and the exercise of our rights or the rights of third parties, and communicating with you.

3.2.3
We may use personal data provided to us by fellows, contributors and other participants in 21Hundred’s programmes and offerings to communicate about, document and promote our work. This may include your name, image (including photographs, video and audio recordings), and biographical information, which may be published in our print and digital publications, on our website, across social media channels, and in other communications materials. Where required under applicable law, we will rely on your consent for such use, and you may withdraw your consent at any time. In other cases, we may rely on our legitimate interests in promoting and communicating about our work, taking care to ensure that such use is proportionate and does not override your rights and freedoms.

3.2.4
We may also anonymise your personal information in such a way that you may not reasonably be re-identified, and we may use this anonymized information for any other purpose.

3.3 Who has access to your personal data

3.3.1
21Hundred will hold your personal data securely in accordance with the Act and the GDPR.

3.3.2
We may share your personal information with third parties to facilities your access to 21Hundred’s offerings.

3.3.3
Third parties will only process your personal data on our instructions and where they have agreed to treat your data confidentially and to keep it secure. We only permit them to process your personal data for specified purposes. We do not allow our third-party service providers to use your personal data for their own purposes nor to keep your data after the processing is complete. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

3.3.4
Where required by law, we may share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party. For example, we may share information where required by law for contact tracing purposes. 

3.3.5
Whenever your data is shared, we will always seek to share the minimum amount necessary to fulfill the purpose.

3.3.6
Because we operate internationally, the recipients referred to above may be located outside the jurisdiction in which you are located. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected.

3.4 How your personal information is protected and stored

3.4.1
We implement physical, technical and organisational security measures designed to safeguard the personal data we collect and process. These measures are aimed at providing ongoing integrity and confidentiality for your personal data.

3.4.2
We retain your personal data for only as long as necessary and only to the extent that we have an ongoing relationship with you, after which we will delete your information from our systems. When deciding how long to keep your personal information after our relationship with you has ended, we consider our legal obligations and our business retention policies. We may also retain records to investigate or defend against potential legal claims