PRIVACY POLICY

This Privacy Policy explains how we collect your personal data on the ICMC RSC website (“the Site”) and its affiliates that post or link directly to the Site, how we protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. ICMC RSC may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. By continuing to use the Site you agree to be bound by the revised Privacy Policy.

This Privacy Policy applies only to personal data that is collected through the Site and does not apply to our offline collection of personal data.

We are not responsible for the privacy of any information you reveal or post in any public forum (e.g. message board or chat room), or for the privacy practices of web sites that are operated or owned by third parties.

1.What information do we collect?

ICMC RSC is the designated Resettlement Support Center and implementing partner for the U.S. Department of State in Turkey and the Middle East region.The personal data of individuals at different stages of the U.S. Refugee Admissions Program is collected and stored in WRAPS software program and accessed by ICMC RSC.We gather two basic types of information: Personal Data and Monitoring Data.

Collection of Personal Data

Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, physical address, or phone number ("Personal Data"). ICMC RSC requests Personal Data from you when you register on the Site. The registration process requests that you provide ICMC RSC with your personal email address, United Nations High Commissioner for Refugees (UNHCR) Case Number and your name to verify further access to the Site, and agree to the Terms presented at the time of registration. We will keep an archive of the email requests. We will not store this information as it is already being stored by the Government of the United States of America (“US Government”). The primary purpose of collecting Personal Data at registration is to simply verify the information provided against US Government records. In addition to information collected during registration, ICMC RSC may collect Personal Data voluntarily provided by you, including in emails to the Site, online forms, registration forms, surveys, etc. Providing this information is always up to you. Information about your case can be accessed by using your UNHCR Case Number and password. To be useful, your case information must be stored on the Site, and is accessible to any Site visitor who knows your UNHCR Case Number and password. For this reason, we advise that users safeguard their UNHCR Case Numbers and passwords carefully and do not disclose this information to any other person.

Use of Cookies

The Site uses cookies to help you more easily interact with the Site. When you visit our Site, we might store some information on your computer in the form of a “cookie." "Cookies" are small text files a Web site can use to recognize repeat visitors, facilitate the visitor’s ongoing access to and use of the site, and allow a site to track usage behavior and compile aggregate data that will allow content improvements.

Cookies are not programs that come onto a visitor’s system and damage files. Generally, cookies work by assigning a unique number to the visitor that has no meaning outside the assigning site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows the visitor to deny or accept the cookie feature. If cookies are disabled in this manner, however, all features of the Site may not operate as intended. Information about the procedure you are required to follow in order to disable cookies can be found through your Internet browser. We expect our service providers to honor any decision by you to block or disable cookies in connection with the Site.

Other personal information

In addition to Personal Data, ICMC RSC and its service providers may collect and/or track information that by itself cannot be used to identify or contact you, e.g., demographic information, domain names, computer type, browser types, screen resolution, and other anonymous statistical data involving the use of the Site ("Monitoring Data"). We use Monitoring Data to help us understand who uses the Site and to improve it.

Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user. Additionally, we may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site.

2.Use of Data Collected

Fulfillment of Requests: ICMC RSC may use your Personal Data to fulfill the purpose for which such Personal Data was provided (e.g., to deliver services).

Internal Purposes: We may also use Personal Data about you for our internal purposes, such as data analysis, editorial and feedback purposes, providing user support, customizing and improving the content and layout of the Site, statistical analysis of user’s behavior, administering individual accounts, and meeting government regulatory requirements.

Administrative Communications: In addition, ICMC RSC reserves the right to use Personal Data to send to you important information regarding the Site, your account status and changes to the Terms and Conditions, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of the Site. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.

Monitoring Purposes

User data may be monitored for internal or external purposes such as researching and identifying needs. This data does not personally identify individuals; we may use such information to improve our services. In addition, we reserve the right to share monitoring data with partners, stakeholders and other third parties, for any purpose. In some instances, we may combine Monitoring Data with Personal Data (such as combining your name with your geographic location). If we do combine Monitoring Data with Personal Data, the combined information will be treated by us as Personal Data as long as it is so combined.

3.Disclosure of Personal Data Collected

Third Party Service Providers We work with third parties who provide services including but not limited to data analysis, order fulfillment and other services of an administrative nature. We reserve the right to share Personal Data about you with such third parties for the purpose of enabling these third parties to provide such services in a manner consistent with our obligations.

Affiliate Communications ICMC RSC reserves the right to transfer Personal Data among our affiliates (the details of which can be found on ICMC RSC’s web site) to allow our affiliates to contact you if need be.

Compliance with local and international legislation Notwithstanding any other provision of this Privacy Policy to the contrary, we reserve the right to disclose Personal Data about you to others as we believe to be appropriate (a) to comply with local legal requirements and processes; (b) to protect the rights, privacy, safety or property of ICMC RSC and its service users; and (c) to permit us to pursue available remedies or limit the damages that we may sustain.

4.Your Choices Regarding Personal Data Collection and Use

To the extent the laws of your country entitle you to review, modify, correct, change, update, block (so that ICMC RSC continues to hold your Personal Data but temporarily refrains from processing it), remove or anonymize Personal Data about you that ICMC RSC has collected, you may exercise this right by making a request via postal mail, e-mail or telephone using the contact information below. However, such requests may require you to register again with ICMC RSC in the event you later wish to access the Site. Where the laws of your country require it, you may ask ICMC RSC to certify that it has notified the entities to whom your Personal Data has been transferred, or of any such changes to or removal of your Personal Data. In the event you make such a request, we may need to verify your identity before implementing your request. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. We are not responsible for removing or suppressing information from the databases of third parties with whom we have already shared Personal Data about you.

5.Links

The Site may contain links to other Internet web sites. These linked sites are not under ICMC RSC control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and ICMC RSC does not endorse, and is not responsible for, the privacy practices or the content of these web sites. If you provide any Personal Data through any such third-party web site, your transaction will occur on such third party's web site (not the Site) and the Personal Data you provide will be collected by, and controlled according to the privacy policy of that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. Please note that this Privacy Policy does not address the privacy or information practices of any third parties, including without limitation, affiliated entities that do not post or link directly to the Privacy Policy.

6.Security Measures

ICMC RSC has established reasonable precautions to protect collected Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction, which include contractual, administrative, physical, and technical steps. Technical measures may include use of firewall protection and encryption technology where ICMC RSC deems such measures are appropriate. Please note that while ICMC RSC has endeavored to create a secure and reliable site for users, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Site or that is stored by us. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us in accordance with Section "Contact Information for ICMC RSC") below (note that if you choose to notify us via postal mail, this will delay the time it takes for us to respond to the problem).

7.Data Integrity

ICMC RSC will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. ICMC RSC will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete (as provided by you), and current (although we depend on you to update or correct your Personal Data whenever necessary).

8.Export of Personal Data

You acknowledge and consent to the fact that Personal Data provided by you or collected by us may be stored and processed by us in Turkey which may provide a different level of data security than in your country of residence. You also acknowledge and consent to the fact that we may, at our discretion, store and process such data in other countries and we will endeavor to protect the Personal Data under our control wherever it is processed or stored.

9.Enforcement

ICMC RSC periodically will review its compliance with this Privacy Policy. ICMC RSC will also review and respond to any formal written complaints that we received from you. ICMC RSC will cooperate with the appropriate regulatory authorities to resolve any complaints that cannot be resolved between us.

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