Privacy Statement

Last updated May 2018

Grain of Wheat exists to encourage needy children with the message of God’s
love, develop their potential and equip them to become agents of transformation within their community. Grain of Wheat is actively pursuing this mission with children between 4 and 14 years of age, working in about 30
countries.
To further this global mission, Grain of Wheat and its various related ministry organizations (Grain of Wheat) may collect, process, use, and share your personal information. The purpose of this Privacy Statement is to explain to you how Grain of Wheat might use your personal information and how Grain of Wheat takes seriously its obligation to you to protect your rights and your personal information.
Where we use the terms “Grain of Wheat,” “we,” “us,” and “our,” we refer to Grain of Wheat International, a non-profit organization, and its subsidiaries and affiliated organizations. “Personal information” generally refers to all data that directly or indirectly relates to you, but “personal information,” “personal data,” or “personally identifiable information” and other terms may apply based upon applicable law and will carry the meaning of those applicable laws.
From time to time, we may update this Privacy Statement, so we encourage you to review this statement periodically, paying special attention to the “LAST UPDATED” date above. In certain circumstances, Grain of Wheat may contact you to specifically notify you of changes to this Privacy Statement.

Grain of Wheat’s Commitment to Data Protection

It is the global policy of Grain of Wheat to exercise a high standard of care in its handling of the personal information it collects, processes, uses, and shares. Grain of Wheat will maintain appropriate policies and processes throughout the global mission to enhance the protection of personal data and ensure compliance with applicable laws and regulations. Grain of Wheat is also committed to the periodic review and augmentation of these policies and processes as part of its Global Privacy Program.

Laws That Apply to This Privacy Statement

Grain of Wheat is a global organization which maintains data protection policies and practices consistent with accepted international data privacy principles. These policies supplement national data privacy laws, and any national law takes precedent in the event it conflicts with Grain of Wheat’s policies. In Europe, the General Data Protection Regulation (GDPR) is in effect as of May 25, 2018. If GDPR and/or other EU privacy laws apply to you, this Privacy Statement describes how you can exercise your rights.

What Kinds of Information We Collect

Grain of Wheat collects the following types of personal information:

Contact information: Includes phone number, physical address, SMS, email
address, telephone number, social media profile details.
Demographics: Includes information about who you are, where you live, and what programs and activities in Grain of Wheat may be of interest to you.
Employment information: Includes information required to process your employment application and complete your employee onboarding process, such as employment history, references, criminal conviction records, unique qualifications or vocational preferences.
Financial History: Includes historical information on your donations to Grain of Wheat, services, or goods purchased from Grain of Wheat, other financial transactions you have entered into with Grain of Wheat.
Identity Data: Includes name, date of birth, gender, marital status.
Information about Personal Beliefs: Includes religious information.
Payment Information: Includes bank account and routing numbers, credit card/debit card numbers, check number, other pertinent financial details.
Requests and Preferences: Includes your preferences for how Grain of Wheat will communicate with you, customizations you have made to any Grain of Wheat account.
Volunteer Information: Includes information required to process your volunteer application and complete your volunteer onboarding process, including references, criminal convictions records, unique qualifications.
Grain of Wheat information: Includes information on your history and engagement with Grain of Wheat.

How We Use Your Personal Information

Grain of Wheat uses the personal information you provide to better serve your requests and to connect you further with the mission and ministry activities of Grain of Wheat. Whether you are involved in a Grain of Wheat club or camp program or donating your time and/or money to our missional objectives, Grain of Wheat will generally use your personal information to achieve its legitimate interests related to our organizational mission. We do not sell, lease, or rent your personal information to others. Grain of Wheat will only process your personal information in accordance with an appropriate legal basis and only for the purposes described in this Privacy Statement. The table below provides a list of examples of how we may use your information, the types of information involved, and the legal basis for our use of your information.

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How We Use Your Personal Information

The Types of Personal Information Involved

Legal Basis

Examples and Explanations
To contact you with information about the ministry activities that Grain of Wheat offers in your local area. Identity data, Contact information Legitimate Interests A Grain of Wheat staff member or volunteer may use your name and phone number or email to invite you to a Grain of Wheat club activity in your local area.
To facilitate your attendance at a Grain of Wheat camp and to follow up with you after your attendance. Identity data, Contact information, Required Health Data, Requests and Preferences, Demographics, Payment Information, Travel Information Contract We think you will have the best week of your life if you attend a Grain of Wheat camp. We will need certain information from kids and parents in order to facilitate the camp experience.
To facilitate your participation in a Grain of Wheat trip. Identity data, Contact Information, Required Health Data, Requests and Preferences, Demographics, Payment Information, Travel Information Contract Grain of Wheat has some amazing short term mission trips, but we need personal information to assist with coordinating travel and communicating important information about the trip.

To assist you in establishing an account on Grain of Wheat’s network.

Identity Data, Contact Information, Requests and Preferences, Demographics, Security credentials.

Contract and Legitimate Interests

 Whether you are attending one of our events or are a faithful donor to Grain of Wheat, we want you to be able to easily interact with

us. Therefore, we use different network solutions

to enhance your

experience with Grain of

Wheat.
For electronic marketing communication related to Grain of Wheat’s ministry activities or related to opportunities to donate to Grain of Wheat. Identity Data, Contact Information Consent or Legitimate Interests We love to let you know about Grain of Wheat opportunities of which you may not already know, but we don’t want to send you communications you don’t want. If you have engaged with us before, we believe we can legally contact you with electronic marketing communications. Howeve r, we want you to be in control, so please let us know if you don’t want to receive this kind of information.

For physical communication (e.g. post, telephone calls, etc.) related to Grain of Wheat activities.

 Identity Data, Contact Information Legitimate Interests We still use the postal service from time to time to communicate with you about your engagement with Grain of Wheat and to let you know important updates about our work with kids.
For non- marketing electronic communication s to keep you informed on Grain of Wheat news and updates. Identity Data, Contact Information Legitimate Interests Our staff members often update interested donors and friends with stories and information on what they are doing in their ministries.

To allow you to apply to serve Grain of Wheat as a staff member or a volunteer.

 Identity Data, Contact Information, Information about your Personal Beliefs, Requests and Preferences, Security Credentials, Demographics, Grain of Wheat Information Contract

Grain of Wheat carefully vets potential staff and volunteers to ensure their fitness to join in our work with kids.
To facilitate your registration for a Grain of Wheat fundraising activity and follow up with you after the event. Identity Data, Contact Information, Payment Information Contract A Grain of Wheat staff member or volunteer may invite you to join in a local golf tournament or banquet to learn more and support the work of Grain of Wheat in your local area.
For contact management. Identity Data, Contact Information, Requests and Preferences, Demographics Legitimate Interests We work hard to manage your information within our system in the most efficient way possible so we can quickly respond to your requests related to Grain of Wheat or related to your rights or personal information.
To provide ministry services such as spiritual guidance or Biblical counsel. Identity Data, Contact Information, Information about your Personal Beliefs Legitimate Interests We believe God loves you and God loves kids, and our staff and volunteers want to be present in the lives of kids to hear what they are going through and demonstrate the love of Christ.
To employ you as a Staff Member of Grain of Wheat. Identity Data, Contact Information, Information about your Personal Beliefs, Requests and Preferences, Security Credentials, Demographics, Employment Information Contract and Legal Obligations In order to work for Grain of Wheat, you must provide certain personal information to facilitate your employment.
To facilitate your volunteer activity for Grain of Wheat. Identity Data, Contact Information, Information about your Personal Beliefs, Requests and Preferences, Security Credentials, Demographics, Volunteer Information Contract and Legal Obligation s In order to volunteer for Grain of Wheat, you must provide certain personal information to facilitate your volunteering.
To process your donations. Identity Data, Contact Information, Payment Information Contract and Legal Obligations When you give to Grain of Wheat, we will ask you to provide information necessary to complete your donation and create appropriate records.
For legal reporting obligations. Identity Data, Contact Information, Payment Information, Financial History, Employment Information, Volunteer Information Legal Obligations Grain of Wheat is subject to certain government reporting obligations and this reporting may include your personal information but only to the extent that Grain of Wheat is legally obligated to supply this information.
To solicit feedback from you on Grain of Wheat ministry activities, good and services. Identity Data, Contact Information, Requests and Preferences, Security Credentials, Demographics, Grain of Wheat Information Legitimate Interests You may be asked from time to time to provide feedback on an event so that we are constantly getting better.
To respond to your requests. Identity Data, Contact Information, Requests and Preferences, Security Credentials, Demographics Legal Obligation s We use your personal information to quickly respond to any request you have for Grain of Wheat.
To respond to your complaints. Identity Data, Contact Information, Requests and Preferences, Demographics Legal Obligation s We use your personal information to quickly respond to any complaint you have against Grain of Wheat and to quickly respond to any concern about your rights and personal information.
To satisfy child safety laws and regulations. Identity Data, Contact Information, Employment Information, Volunteer Information Legal Obligation s Grain of Wheat performs periodic criminal background checks and driver’s questionnaires as part of our commitment to the highest standards of child safety.

How Information is Collected

We obtain personal information about you in the following ways:

  1. Personal interactions: The ministry of Grain of Wheat is defined by relationships. Our staff members and volunteers interact regularly with kids, parents, coaches, donors, and many other individuals. These personal interactions are a primary avenue by which Grain of Wheat gets information from you.
  1. Direct Requests: You may have reached out to Grain of Wheat on your own or visited one of our If you have inquired about a Grain of Wheat activity, engaged in a Grain of Wheat activity, made a donation, registered for an event or camp, or have otherwise chosen to give Grain of Wheat Information, we have your personal information. Please read this Privacy Statement carefully to understand your rights and our commitments related to your personal information.
  2. Cookies and Other Automated Technologies: If you have visited and/or registered on a Grain of Wheat website, some of your personal information may have been gathered by cookies or other automated technologies utilized on the Grain of Wheat network. Read the section below on Grain of Wheat’s use of cookies for additional information.

How and When We Might Share Your Information

Grain of Wheat does not generally disclose personal information with anyone outside the organization. However, Grain of Wheat is a global organization who may, for the purposes described above, share your personal information with:

  1. Other parties within or associated with Grain of Wheat International.
  2. Public or regulatory organizations for obligatory purposes described above.
  1. Third-party service providers Grain of Wheat has contracted to assist in the types of uses described above, including web-based contact management service providers, cloud service providers, companies assisting in the processing of your donations or other financial transactions, and email marketing service Grain of Wheat has entered into contracts with these third party service providers without neglecting the protection of your personal information.

International Data Transfers

Grain of Wheat is a global organization operating in different parts of the world through branch organizations, subsidiaries, and affiliates. Therefore, Grain of Wheat may transfer your personal information from one country to another. All individuals in the European Economic Area or the United Kingdom need to be aware that we may transfer your personal information outside of the European Economic Area or the UK for processing.

Any transfer of personal information from country to country will be done with appropriate safeguards and in compliance with applicable laws. Grain of Wheat and its European subsidiaries and affiliates have established standard contract clauses to govern the transfer of data from the European country to other countries, such as the United States.

Your Rights

If you are located in the European Economic Area or the United Kingdom, you have certain rights related to your personal information. If you wish to exercise any of those rights, please email Grain of Wheat at info@grainofwheat.org. We will respond to your request within 30 days. We may need to verify your identity in order to process your request.

These European rights include:

  1. Right of access

You have the right to know that we are processing your personal information, how we are processing this information, and for what purposes. This Privacy Statement is intended to provide the transparency necessary for you to know this information, but you can certainly make additional inquiries to Grain of Wheat by emailing info@grainofwheat.org.

  1. Right to Edit and Update Information

You have the right to rectify inaccurate information, update your personal information, and supplement incomplete information in the Grain of Wheat networks. Grain of Wheat’s network solutions will often allow you to make these changes on your own by managing your online Grain of Wheat account. Where this feature is not accessible, you can contact Grain of Wheat by emailing info@grainofwheat.org, and we will address your request without undue delay.

  1. Right to Delete Personal Information

You have the right to request us to delete your personal information for the following reasons:

  1. If the data is no longer necessary for the purposes it was
  2. If you withdraw previously given consent where consent is required to process the
  3. If you object to Grain of Wheat processing the data in a certain way or for certain purposes and Grain of Wheat does not have legitimate grounds to continue processing the
  4. If your personal information has been unlawfully
  5. If your personal information must be erased to comply with a legal obligation.
  6. If the personal information has been collected in relation to the offer of Information Society Services as defined in Article 8(1) of the General Data Protection

We may be required to reject your request to delete your information for the following reasons:

a. For exercising the right of freedom of expression and information.

b. For compliance with a legal

c. For reasons of public interest as described in Article 17 of

d. For the establishment, exercise or defense of legal claims.

To make a request to delete information, you can email Grain of Wheat at info@grainofwheat.org. We will notify you within 30 days as to whether your request has been accepted or if and for what reason we cannot fulfill your request.

4. Right to Request the Limitation of Processing Personal Information

You have the right to restrict our processing of your personal information for the following reasons:

  1. If you believe your personal information is inaccurate, you can request that we limit our processing of the data until its accuracy is verified.
  2. If the processing of your data is unlawful, you may either request erasure as described above or request certain.
  3. If the controller does not need the information for the purposes above but must retain the information for the establishment, exercise or defense of legal.
  4. If you have objected to the processing of your personal information and there is a pending determination as to whether our legitimate grounds to process override your rights described

As with any request for erasure of your personal information, you also have the right to be notified by us about a restriction in the processing of your personal information.

You can make this request by emailing Grain of Wheat at info@grainofwheat.org.

5. Right to Portability

You have the right to request us to send you your personal information in a structured, commonly used, machine-readable format so that it can easily be transferred and used by a third party if:

  1. You provided us with the
  2. The processing of your personal information is based on your consent or required for the performance of a contract; or
  3. The processing is carried out by automated

You can make this request by emailing Grain of Wheat at info@grainofwheat.org.

6. Right to Object and Automated Individual Decision-making

You have the right to object to our processing of your data when our legal basis for processing is Grain of Wheat’s legitimate interests based on your particular situation. Upon receiving an objection from you, Grain of Wheat will cease to process your information unless we can demonstrate compelling legitimate grounds for the processing which overrides your rights and freedoms.

Particularly, you have the right to object to the processing of your personal information related to direct electronic marketing.

You also have the right to object to our processing of your information where decisions on processing are made by automated processing which has a legal or other significant impact on you.

You can make this request by emailing Grain of Wheat at info@grainofwheat.org.

7. Right to Withdraw Consent

Grain of Wheat is primarily processing your information based on our legitimate interests and other obligations. However, where you have given consent to us to process your personal information, you have the right to withdraw that consent and we will promptly respond.

You can make this request by emailing Grain of Wheat at info@grainofwheat.org.

8. Right to File a Complaint with the Data Protection Authority

We want to provide the best service to you related to these requests and resolve any issue you have with Grain of Wheat related to the processing of your personal information. You, however, always have the right to contact your local data protection authority for assistance or to make a complaint.

While the rights explained above do not apply to those outside of the European Economic Area and the UK, as a matter of rights and freedoms, we still do care about your questions and concerns related to your personal information. If you are not located in the European Economic Area or the United Kingdom, you can contact Grain of Wheat at info@grainofwheat.org to make a request related to your personal data.

Security

To safeguard and secure the information we collect, Grain of Wheat has applied appropriate physical, electronic and managerial procedures to prevent unauthorized access and maintain data accuracy. The Secure Socket Layer (SSL) protocol is used to encrypt and protect all Internet data transmissions. The padlock icon in your browser’s window signifies that a site is secure.

Sometimes password protection is used to protect your privacy and security. Grain of Wheat will continue to augment current security procedures and adopt new security protocols as necessary to meet the standard of care we have promised in our policies and in this Privacy Statement.

Grain of Wheat is also committed to a prompt response to any potential data breach and has instituted a Data Breach Protocol Process which includes timely notices as required by applicable law.

Information Collected by Cookies or Technology

 

Grain of Wheat websites may use cookies to recognize you and may allow you to automatically log in without re-entering your user name and password every time you visit our site. The cookies are encrypted and may store limited personally identifiable information about you, including your name, user name and email address. If cookies are disabled on your browser, you may be able to still use a Grain of Wheat website, but you will be required to enter your password each time you visit.

Information Related to Children

In general, Grain of Wheat websites are informational sites for parents and children about Grain of Wheat. It is our intention to provide a safe, fun environment where children and their parents may explore Grain of Wheat, their own Grain of Wheat club and other Grain of Wheat activities. None of Grain of Wheat’s websites knowingly solicit personal information from children under the age of 13, except where personal information must be solicited from children and/or parents to facilitate participation in Grain of Wheat events or activities.

We care about children’s privacy and we take great care to safeguard the personal information of all children. We do not require a child to supply us with any personal information other than is necessary to participate in a specific activity, and we never condition a child’s participation in an activity on the child’s disclosing more personal information than is reasonably necessary to participate in that activity. All personal information we do collect can only be accessed by authorized Grain of Wheat staff and volunteers, and only those people who require access may see this information for the purposes described above. We work diligently to preserve the confidentiality, security and integrity of that information.

As a ministry to children, Grain of Wheat is deeply committed to the safety and welfare of kids. We have policies and procedures designed to ensure compliance with applicable privacy laws and employ generally accepted best practices, especially as it relates to parental notice and consent. Parents have the right to request at any time that the information collected about their child be removed from Grain of Wheat’s networks and databases. You can contact Grain of Wheat at info@grainofwheat.org.