NAW GDPR Privacy Notice

NAW “Towards One Nation نحو الوطن ” is strongly committed to protecting your privacy and complying with your choices. This Privacy Notice describes NAW’s privacy practices in relation to information that we collect from you through our online application model, our website, our social media sites and via other services provided by us offline.
Both personal and non-personal information collected is safeguarded according to the highest privacy and data protection standards adopted worldwide. From our inception, we committed to a robust and effective data protection program which complies with existing law and abides by the data protection principles.
We recognize our obligations in keeping on updating and expanding our program to meet the demands of the GDPR.

1. Who we are
2. What information we collect about you
3. How we collect the information
4. How we use that information
5. How we share information that we collect
6. How we store and secure information that we collect
7. Your rights as a data subject
8. How you can access and control your information
9. Other important details

This Privacy Notice does not apply to the practices of third parties that NAW does not own or control.

1.1 Who we are

NAW “Towards One Nation نحو الوطن ” is a platform for political change and socio-economic renewal. We want to drive change by enabling the emergence of qualified, independent-minded and honest political leaders committed to serve the national interest and be held accountable to their constituents.
If you have a query in relation to how your data is handled, you can contact us by email:
[email protected]

1.2 What information we collect about you

NAW collect Personal Data and Other Information in a number of ways:

• Personal Data. “Personal Data” is information that, directly or indirectly, identifies you or another individual and which may include: name, title, postal address, telephone number, email address, civil registry number, browser and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
• Special categories of Personal Data (sensitive data). While NAW does not, in general, collect or process many types of special categories of personal data, it may be necessary to obtain the nationality of individuals for the sole purpose of assisting individuals to obtain a Lebanese passport or Lebanese ID. In addition, an individual’s political opinion is considered to be a special category of personal data under the General Data Protection Regulation (the GDPR).
• Other Information. “Other Information” is any information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymised. We use this information for other purposes as described below.

1.3 How we collect the information

NAW collect Personal Data and Other Information in a number of ways:

	Purpose of collection
From you:	NAW collects information such as your name, address, email, phone number and civil registry number, when you voluntarily provide it. We collect your country of residence and your Lebanese registry number so we may have better predications and thus direct our efforts to enable the Independent Candidates List to win maximum votes.
Offline:	We may collect information from you offline, such as during on-site visits, during phone calls, or when you contact us.
Via recruitment and employment processes:	We will process certain personal information about our employees, that we collect during the job interview process, at the start of employment and in the course of employment. We process this personal data to the extent permitted or required under applicable law, for purposes connected with employment, such as human resources, payroll management and administration.
Via volunteer processes:	We will process certain personal information about our volunteers such as name, address, email and phone number, when you voluntarily provide this information.
Via your browser or device:	Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the site you are using. Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the website, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services, such as Google Analytics. NAW may use IP Addresses to calculate usage levels of the web site, to administer the site and to diagnose problems with servers.
Via cookies and other similar technologies:	“Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the website. When you visit a website, it can send one or more cookies to your device. These cookies enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse and enhance the level of services and functions provided.

1.4 How we use that information

We use Personal Data:

• To keep you updated with NAW news.
• To provide you with necessary information on how and when to register and vote for the 2022 Parliamentary elections.
• To provide you with information about the list of independent candidates that will be formed by a coalition of emerging political parties and groups, independent candidates, youth groups and civil society.
• To keep you updated on NAW fundraising events and reporting.
• To assist you in obtaining a Lebanese passport or Lebanese ID.
• To process funding donations made by you.
• For our business purposes, such as data analysis and simulation reports identifying trends, determining the effectiveness of our operations.
• For recruitment, employment and volunteer purposes, such as staff management, volunteer management, performance review, training records, appointments, removals, personal development and administration.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Members; (f) to protect our rights, privacy, safety or property, and/or that of our Members, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Our legal basis for collecting and using the Personal Data described above is that of consent. We will collect and use your Personal Data where you have given us consent to do so. When you provide your personal information, you consent that it can be used for the above purposes and that NAW is an authorised holder of such information. When you press continue, you are providing your consent to occasionally receive information from us.

You can withdraw your consent at any time by opting out of our processing activities. In each communication from us you will have the opportunity to unsubscribe from further communications; alternatively, you may contact us to express your choices at:
Email: [email protected]
Our legal basis for processing Personal Data of employees will be in the instances where we need the Personal Data to perform a contract with you or in order to enter into a contract with you.

1.5 How we share information that we collect

We may pass your personal data on to electoral delegates in the instance that they require a list of residents within his or her voting area.
We may release Personal Data as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other companies and organisations for the reasons given under Section 1.4 above.
We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. For example, Other Information, i.e. anonymised data, may be made public or issued to volunteers. This is information that cannot be used to reveal your identity. If we are required to treat Other Information as Personal Data under applicable law, then we would use or disclose it in the same way that we use and disclose Personal Data. We will not rent or sell your personal data.

1.6 How we store and secure information that we collect

We have implemented appropriate organisational, technical, and administrative measures to protect Personal Data within our organisation, including security controls to prevent unauthorised access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorised access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Us section below.

1.7 Your rights as a data subject

If you are habitually located in the European Union or European Economic Area, at any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
• Right to complain and judicial review: in the event that NAW refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in Section 1.9 below.

To avail of any of these rights, please contact us, using the details in the Contact Us section below.

1.8 How you can access and control your information

If you would like to access, correct, amend, remove, object or limit the use or disclosure of any Personal Data about you that has been collected and stored by NAW, or have it transferred to another organisation, please notify us at [email protected] so that we may consider and respond to your request in accordance with applicable law.

For your protection, we only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we need to verify your identity before implementing your request. We will action your request within one month.

Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change or deletion

1.9 Other important details

How long NAW will retain your Personal Data

Your personal data will be retained for 1 year from the date on which the Election is held. This is to facilitate further reporting and analysis. Other information, i.e. anonymised data, may be held indefinitely.

Third Party Sites

Some websites, social media and applications permit you to link to other websites on the Internet through direct links or through applications such as “share” or “like” buttons, and other websites likewise may contain links to our sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Privacy Notice. We encourage you to review the privacy policies found on such other websites, services and applications to understand how your information is collected and used by them.

Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organisations, such as Apple, Facebook, Google, LinkedIn, Microsoft, RIM, Twitter or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Data you disclose to other organisations through or in connection with the Apps or the Social Media Pages.

Personal data of Children

NAW does not knowingly or specifically collect information about people under the age of 16. While an individual must be 21 years or older to vote, personal data of those aged between 16 and 21 years may be processed by NAW, with the individual’s consent, as these individuals can become the voice of mobilisation, as they will have a vote in the future.

Sensitive (i.e. Special Categories of Personal Data) Information

We ask that you not send us or disclose sensitive Personal Data (e.g. information related to racial or ethnic origin, sexual orientation, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the website, applications or via other means.

Changes to this Privacy Notice

NAW may amend this Privacy Notice from time to time. The “date amended” appears at the bottom of this privacy notice and this date indicates when the Privacy Notice was last revised.

Enforcement of this Privacy Notice

If for some reason you believe NAW is not adhering to this privacy notice, please notify us using the detail in the Contact Us section below, and we will do our best to promptly make corrections.

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact:
Nahwal Watan,
12th floor Freeway Center
Dekwaneh
Lebanon
Email: [email protected]
Because email communications are not always secure, please do not include bank account information or other sensitive (special categories of personal data) information in your emails to us.

Your right to make a complaint

NAW will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

Privacy Notice – Date Amended: 10 August 2021