This Privacy Policy (“Privacy Policy”) applies to the App accessible at  google play and the cloud-based technology platforms also accessible through that App, the video players used to view Youth Net & Counselling programmes, and the mobile applications (“Platform”, and together with the App, all owned and operated by Youth Net & Counselling, a local Non-Governmental organization registered with Malawi Government (Trustees Incorporation (1962) Act in October 1999 and with NGO (2000) Act in November 2003 (“Youth Net & Counselling”, “we”, or “us”). This Privacy Policy describes how Youth Net & Counselling collects and uses personal information collected through the Website and the Platform. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

THIS PRIVACY POLICY SETS OUT:

•     The information we collect about you

•     How we use the information we collect

•     Who we give your information to

•     Control of your information

•     Your access to your information and how long we keep it

•     How we protect your information

•     Where we store your information

 

•     Information about our participation in Privacy Shield

•     Public forums

•     Information about enforcement and dispute resolution

•     Changes to this Privacy Policy

•     Contact us

 

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By engaging with the Website and the Platform you acknowledge you have read and understood this Privacy Policy. Data protection laws require companies to describe their role and responsibility when handling personal information.

When you engage with the App, then;

  • Youth Net & Counselling is the data controller for information provided directly by you, including your phone number, name and email
  • When you sign up as a user of the Platform (as defined in the Terms of Use), Youth Net & Counselling is the data controller for all personal information provided by that user and collected by the Platform as the user accesses and uses it.

THE INFORMATION WE COLLECT ABOUT YOU

We value your trust. In order to honor that trust, Youth Net & Counselling adheres to ethical standards in gathering, using, and safeguarding any information you provide.

We collect and process the following personal information from you:

INFORMATION YOU GIVE TO US:

This is information about you that you give us directly when you interact with us. You may give it to us by filling out a form on our App, corresponding with us by phone, e-mail, or at an in-person event. It also includes information shared when you submit a query, report feedback about or a problem within our App, or any of the other Interactive Services (defined in the Terms of Use). When you create an account on the App, we require you provide first name, last name, phone number and email address.

INFORMATION WE COLLECT ABOUT YOU FROM YOUR USE OF OUR APP:

We will collect information from you each time you make a report on abuse or violence or register through filling the in app forms or when you report an abuse through clicking the panic button which generates an SMS.

HOW WE USE THE INFORMATION WE COLLECT

INFORMATION YOU GIVE TO US:

Youth Net & Counselling uses the personal information you provide in a manner that is consistent with this Privacy Policy. We use your personal information to provide our services in our App, including services arising from any obligations set forth in our line of duty. These services may include following up and providing referral of the reported case of abuse with and to different stakeholders.

WHO WE GIVE YOUR INFORMATION TO

We consider your personal information to be a vital part of our relationship with you and do not sell your personal information to third parties. There are, however, certain circumstances in which we may share your personal information with certain third parties, as follows:

AGENTS, CONSULTANTS AND RELATED THIRD PARTIES:

We share your information with other stakeholders to facilitate case referrals for immediate remedial action for a reported case to ensure perpetrators are taken to task. When we refer a case to a stakeholder to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These organizations are not permitted to use any personal information that we share with them for any other purpose aside from providing services to us.

LEGAL REQUIREMENTS:

In certain situations, Youth Net & Counselling may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or similar legal process served on us or our Site.

We will take reasonable steps to ensure that we only collect that personal information that is relevant for the purposes for which it is to be used. Furthermore, we will not process your personal information in a way that is incompatible with these purposes.

CONTROL OF YOUR INFORMATION

When you register, or otherwise give us personal information, we will not share that information with third parties without your permission, other than for the limited exceptions already listed. It will only be used for the purposes stated in this Privacy Policy. When Youth Net & Counselling is acting as a data processor, we will only process personal information in accordance with the instructions given by the data controller. When Youth Net & Counselling is acting as a data controller, we will act in accordance with your permission to offer you our services and as otherwise instructed by you.

YOUR ACCESS TO YOUR INFORMATION AND HOW LONG WE KEEP IT

Upon request, Youth Net & Counselling will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at executive@yoneco.org cc ict@yoneco.org.

We will provide you with the means to ensure that your personal information is correct and current. If you have registered to use the App, you will be able to change your profile within the App.

You may request deletion by accessing your profile. Alternatively, you may contact us at executive@yoneco.org cc ict@yoneco.org.

We will respond to your request within a reasonable timeframe. Requesting deletion of your account means your personal information is permanently deleted and cannot be retrieved.

If you would like to view your personal information that we hold at any time, you may access your profile from the app.

HOW WE PROTECT YOUR INFORMATION

The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our checkout page, your information is sent over an authenticated and encrypted connection using Transport Layer Security (TLS).

We store your personal information only on servers with limited access that are located in controlled facilities and use a variety of technologies and procedures intended to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Nonetheless, no communication via the Internet can ever be 100% secure, and no security measures can ever be assured to be effective. Accordingly, you are advised to use caution and discretion when determining what personal information to disclose to us.

If you have any questions about security in our App, contact us as follows:

Email: executive@yoneco.org copying ict@yoneco.org

Phone: +265 1 526 199 / +265 888 958 726

WHERE WE STORE YOUR INFORMATION

The data that we collect from you is transferred to, and stored at, a destination in Malawi. Youth Net & Counselling participates in and has certified its compliance with the Malawi Communications Regulatory Authority. For more information on Youth Net & Counselling’s participation in MACRA Privacy Framework, please see below.

INFORMATION ABOUT OUR PARTICIPATION IN PRIVACY SHIELD

Youth Net & Counselling participates in and has certified its compliance with the Malawi Communications Regulatory Authority Privacy Shield frameworks. We are committed to subjecting all information received from the Republic of Malawi and elsewhere which constitutes “personal data” subject to the Republic of Malawi’s privacy laws (“Malawi Personal Data”), in reliance on Privacy Shield, to the applicable Privacy Shield Principles.

Our compliance with applicable Privacy Shield Principles is further described as follows:

COLLECTION AND USE; PURPOSE. Youth Net & Counselling collects and uses Malawi Personal Data as described in the sections above about how we collect and use personal information.

THIRD PARTY DISCLOSURE. We may disclose Malawi Personal Data as described in the sections above about how and when we disclose personal information.

SECURITY. Youth Net & Counselling protects the security of Malawi Personal Data during transfer and storage as described in the sections above about how we protect personal information.

ONWARD TRANSFER. Where Youth Net & Counselling transfers personal data from the Malawi, we do so under the Privacy Shield framework. Youth Net & Counselling maintains contracts with third parties who act on behalf of Youth Net & Counselling and to whom we transfer personal data that restrict their access, use, and disclosure of personal data in compliance with our Privacy Shield obligations. Youth Net & Counselling complies with the Privacy Shield Principles for all onward transfers of Malawi Personal Data, including the onward transfer liability provisions.

ACCESS AND CHOICE. Residents of the Republic of Malawi whose personal data Youth Net & Counselling has directly collected may request access to, and the opportunity to correct, amend, or delete such personal data. To submit such requests or raise any other questions, please contact us at executive@yoneco.org copying ict@yoneco.org. Youth Net & Counselling reserves the right to take appropriate steps to authenticate an applicant’s identity and charge a reasonable fee before providing access and deny requests, except as required by the Privacy Shield principles.

RECOURSE; ENFORCEMENT; LIABILITY. Youth Net & Counselling complies with the Privacy Shield Principles for recourse, enforcement and liability. Youth Net & Counselling uses a third party (outside compliance review) agent to assure compliance with this Privacy Policy and periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely

implemented and accessible and in conformance with Privacy Shield principles. You may direct inquiries or complaints concerning our Privacy Shield compliance to ict@yoneco.org. Youth Net & Counselling will respond within 45 days. If we fail to respond or if our response did not satisfactorily address your concern, you may file a report with our third party dispute resolution provider (free of charge) at dg-macra@macra.org.mw. Youth Net & Counselling has further committed to cooperate with the panel established by the Malawi data protection authorities (MDPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the Malawi in the context of Malawi Personal Data received or transferred pursuant to the Privacy Shield framework, Youth Net & Counselling is subject to the regulatory investigation and enforcement powers of the Malawi Communications Regulatory Authority.

INFORMATION ABOUT ENFORCEMENT AND DISPUTE RESOLUTION

We will conduct compliance audits of our relevant privacy practices to verify compliance with this Privacy Policy. Any Youth Net & Counselling employee that we determine has acted in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment.

Any questions or concerns regarding our use or disclosure of personal information should be addressed to Customer Support at ict@yoneco.org copying executive@yoneco.org. We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of personal information in accordance with the provisions of this Privacy Policy.

Youth Net & Counselling has committed to refer unresolved Privacy complaints to an alternative dispute resolution provider located in the Malawi. If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact our third party dispute resolution provider (free of charge) at dg-macra@macra.org.mw.

CHANGES TO THIS PRIVACY POLICY

As our Site evolves, this Privacy Policy will need to evolve as well to cover new situations. To ensure that you are kept informed of changes, check this Privacy Policy periodically as we will update the date at the top of the document any time we make a change. If we make material changes to this Privacy Policy, we will post the revised policy on this page and will send a notice via email or our Site to all registered users of the Platform. Your continued use of our Site after any such changes constitutes your acceptance of the new Privacy Policy. If you do not agree to abide by these or any future version of the Privacy Policy, you do not have permission to use or access (or continue to use or access) our Site.

CONTACT US

Questions or comments regarding this Privacy Policy should be submitted to Youth Net & Counselling by e-mail or phone as follows:

Email: executive@yoneco.org copying ict@yoneco.org

Phone: +265 1 526 199 / +265 888 958 726

Physical Address: c/o Youth Leadership Development Centre, Along M5 Zomba-Lilongwe Road, Next to Calvary Church, P.O. Box 471, Zomba, Malawi.

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