PRIVACY POLICY
January 2023

Welcome to the Website of Miftah ("we" or "us") at http://www.miftah.org/. Miftah (including
all content under the "http://www.miftah.org" domain name, and referred to herein as the"Website"). This Privacy Policy ("Privacy Policy") supplements and is included as a part of ourWebsite Terms of Service. By accepting the Website Terms of Service, you also agree to thisPrivacy Policy.

1Introduction

1.1

MIFTAH is a not-for-profit organization that works towards two distinct pathways. The firstis to enhance policies and practices in line with civil rights and social justice in Palestine.
This is done through providing evidence, fostering dialogue to formulate policy proposals,and empowering women and youth to uphold these policies. The second pathway focuseson enhancing the promotion of the Palestinian narrative at the international level throughdisseminating facts and figures about Palestine and engaging in dialogue with variousstakeholders.

1.2This privacy policy explains our online information collection and use practices, and thechoices you may and can make about the way we use such information. Please read thisprivacy policy carefully to understand how we use your personal data (as defined below).
Please note that, we may change this privacy policy from time to time, for example when
we update the Website or expand our service and/or activities. Thus, we strongly recommend
reviewing it whenever you visit the Website.

2

Scope

This Privacy Policy applies to web-users visiting Miftah website, within the www.Miftah.org
domain name.

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Applicable Law

3.1

This Privacy Policy is subject to local Palestinian laws and the provisions of applicable dataprotection and privacy laws of the General Data Protection Regulations (“GDPR”). For thepurposes of the GDPR when you use our Website, we are a data “Controller” and you are a“Data Subject” with certain protected privacy rights concerning your “Personal Data.”

3.2"Personal Data"/"Personal Information" in this Privacy Policy means any information
relating to you as a natural person that can be directly or indirectly related to you. Personal
Data generally may include your name, email address, ID number, location, household
information, online ID, and factors specific to your physical, physiological, genetic, mental,economic, cultural or social identity. Your Personal Data may identify you as a person, andthus is often referred to as Personally Identifiable Information ("PII") or PersonalInformation ("PI"). Both PII and PI are included in the term "Personal Data" as used in thisPrivacy Policy.

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Collection of Information

Miftah collects data through automated technologies or interactions. For example, Miftah follows
a standard procedure of using log files. These files log visitors when they visit Websites. The
information collected by log files includes Internet protocol (IP) address, browser type, Internet
Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number ofclicks. The purpose of the information is for analyzing trends, administering the site, tracking users'
movement on the Website, and gathering demographic information.

5Collected Information

5.1

Website statistics: We collect the date, time and length of your visit, browser identification
and IP address for internal use and analysis of website traffic. This information isanonymised and used for statistical analysis only.
Email sign-up to our newsletter: When you provide us with your email address to receive
newsletter updates at that email address, we use this internally and never share it with others.
We will confirm your consent to receive the newsletters regularly, at least every 12 months.
Other personal information: We don't collect and/or use your information without yourpermission.

5.2

5.3

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The Purpose of Collecting your Information

6.1

To allow you to contact us and/or receive information from us;

6.2

To organize or promote events and/or activities;

6.3

To allow you to register to participate in events we organize or co-organize;

6.4

To analyse web statistics and log files, with the aim of improving the functioning of ourWebsite;

6.5

To send you, our newsletter when you provide your consent to us to do so.

6.6

We may use anonymous aggregated information that we collect to improve the design andcontent of our Website, and to enable us to personalize your Internet experience. We also
may use this anonymous aggregated information to analyse how our Website is used, analyse
industry trends, as well as to enable us to offer new programs or services.

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Sharing your data/ Information

7.1

Miftah does not share your personal information with any third-party without yourpermission. Any personal data supplied by you will be retained by Miftah and will beaccessible by Miftah's team on a "need to know" basis. Miftah has put in place appropriate
measures to prevent your personal data from being accidentally lost, used or accessed in an
unauthorized way, altered or disclosed.

7.2

Miftah may only share your personal information to government agencies, regulators andother authorities when necessary for compliance with a legal obligation.

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Storing your Data/Information

8.1

We hold your personal data/information in our Google analytics and Mailchimp accounts.
By providing Miftah with your personal information, you consent to the transfer of yourpersonal information to, and its storage on our Google Analytics and Mailchimp accounts

38.2

Miftah will only retain your personal data for as long as reasonably necessary to fulfil thepurposes Miftah collected it for, including for the purposes of satisfying any legal orregulatory requirements.

9Collection of Information by Others

Our Website may include links that take you to certain third-party websites. Please check theprivacy policies of these other websites to learn how they collect, use, store and share informationthat you may submit to them or that they collect.

10 Legal Basis for Using your Personal Information
We will use your Personal Data under the following legal basis:10.1 Where it is necessary for our legitimate interests and your interests and fundamental rights
do not override those interests;
10.2 Where we need to perform our obligations under a contract we are about to enter into, or
have entered into with you; and;10.3 Where we need to comply with a legal obligation.

11 Our Contact Information
If you have any questions about this Privacy Policy, please contact us at: info@miftah.org.

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