Privacy Policy

1. Introduction

Early Smile Foundation LBG (“Early Smile Foundation,” “ESF,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy applies to personal information collected through https://earlysmilefoundation.org (the “Website”) and through related communications, applications, donations, events, volunteer activities, mentoring, newsletters, and nonprofit programs.

We process personal information in accordance with applicable data protection law, including Ghana’s Data Protection Act, 2012 (Act 843). Where the European Union General Data Protection Regulation (“GDPR”) applies, we also process personal data in accordance with its principles and requirements.

Please read this policy before providing personal information to us. By using the Website, you acknowledge that you have read this policy. Where consent is our legal basis for processing, we will ask for it separately when required, and you may withdraw it at any time.

2. Organization Information

For the personal information covered by this policy, Early Smile Foundation LBG generally acts as the data controller, meaning that we decide why and how that information is processed.

3. Information We Collect

The information we collect depends on how you interact with us. We may collect the following categories:

Information you provide directly

• Identity and contact information, such as your name, email address, telephone number, postal address, organization, and preferred method of contact.
• Application and participation information, such as education, interests, skills, experience, age or date of birth, availability, references, and answers submitted when applying for a program, mentorship, volunteer role, event, or opportunity.
• Donation and transaction information, such as donation amount, date, and transaction reference. Payment card or account details are generally collected directly by our payment provider rather than stored by us.
• Communications, including messages, enquiries, feedback, survey responses, and correspondence with our team.
• Newsletter preferences, including your email address, subscription status, and engagement with updates we send.
• Program records and media, including attendance, safeguarding information, photographs, audio, video, testimonials, or impact stories where appropriate permissions have been obtained.

Information collected automatically

When you use the Website, we and our service providers may automatically receive limited technical information, such as your IP address, browser type, device type, operating system, referring page, pages viewed, and approximate location derived from your IP address. This information may be collected through server logs, cookies, or similar technologies.

Information from other sources

We may receive information from parents or guardians, schools, community partners, referral organizations, event partners, social media platforms, or service providers when it is lawful and appropriate to do so. If you provide information about another person, please ensure that you are authorized to do so and that they understand how we will use it.

Sensitive or special-category information

Some programs may require limited health, disability, safeguarding, or other sensitive information so that we can support participants safely and inclusively. We collect this only where necessary and with an appropriate legal basis, such as explicit consent, vital interests, or another basis permitted by law. Please do not send sensitive information through a general contact form unless we specifically request it.

4. How We Use Information

We may use personal information to:

• respond to enquiries and communicate with you;
• review applications and administer programs, events, mentoring, volunteering, and community activities;
• process and acknowledge donations and maintain financial records;
• send newsletters, appeals, and updates where you have subscribed or where otherwise permitted by law;
• manage relationships with participants, guardians, donors, volunteers, mentors, partners, and supporters;
• protect the safety and wellbeing of children, participants, staff, volunteers, and communities;
• measure, evaluate, and report on our programs and charitable impact, using aggregated or de-identified information where practical;
• operate, maintain, troubleshoot, and improve the Website and our services;
• prevent fraud, misuse, security incidents, and other unlawful activity;
• comply with legal, regulatory, accounting, safeguarding, and governance obligations; and
• establish, exercise, or defend legal claims.

Our legal bases under the GDPR

Where the GDPR applies, we rely on one or more of the following legal bases, depending on the purpose and circumstances:

We do not sell or rent personal information. We do not use personal information for solely automated decisions that produce legal or similarly significant effects.

5. Cookies

Cookies are small text files stored on your device. The Website and services used on it may use cookies or similar technologies for purposes such as:

• Strictly necessary functions, including security, navigation, and form operation;
• Preferences, such as remembering choices you make;
• Performance and analytics, to understand how the Website is used and improve it; and
• Third-party media and services, which may set cookies when external videos, forms, payment pages, social links, or other content is loaded or used.

Where required by law, non-essential cookies will be used only after you have given consent. You can also manage or delete cookies through your browser settings. Blocking some cookies may affect how parts of the Website function. Third-party services control their own cookies, so we encourage you to review their privacy and cookie information.

6. Third-Party Services

We use trusted service providers to operate our Website and nonprofit activities. Depending on how you interact with us, these may include:

• Formspree to receive contact-form submissions;
• MailerLite to manage newsletter subscriptions and email communications;
• Google services for hosted forms, fonts, and related functionality;
• PayPal or other payment providers to process donations;
• Vimeo and YouTube to host or display video content;
• LinkedIn and Instagram when you follow links to our social media pages; and
• website hosting, security, communications, professional, and technology providers that support our operations.

These providers may process personal information on our behalf or as independent controllers under their own privacy policies. We share only information reasonably needed for the relevant service and seek appropriate contractual and security protections where required.

International transfers

Some providers may process information outside Ghana or the country where you live. Where applicable law requires it, we use appropriate safeguards for international transfers, such as adequacy decisions, approved contractual protections, or another lawful transfer mechanism. No method of international transfer or electronic storage is completely risk-free.

The Website may link to sites that we do not control. This policy does not cover their practices, and visiting those sites is subject to their own terms and privacy notices.

7. Data Retention

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including to meet legal, accounting, reporting, safeguarding, donor, grant, dispute-resolution, and recordkeeping requirements.

Retention periods vary according to factors such as:

• the type, amount, and sensitivity of the information;
• the nature and duration of our relationship with you;
• the needs of the relevant program or activity;
• the risk of harm from unauthorized use or disclosure;
• legal, regulatory, contractual, grant, tax, and safeguarding obligations; and
• whether the purpose can be achieved through anonymization.

When information is no longer required, we will securely delete, destroy, or anonymize it, subject to any lawful need to preserve it. Unsubscribing from communications may not remove the limited record we need to maintain your opt-out preference.

8. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful loss, misuse, alteration, unauthorized access, disclosure, or destruction. Measures may include access controls, account security, secure service providers, staff and volunteer confidentiality practices, data minimization, backups, and periodic review of how information is handled.

Access is limited to people who need the information for legitimate nonprofit or service purposes. Those people are expected to handle it confidentially and responsibly.

No website, email, or storage system can be guaranteed to be completely secure. Please use care when sending personal information online and contact us promptly if you believe your information may have been compromised.

9. Your Rights

Depending on where you live and the law that applies, you may have the right to:

• be informed about how your information is used;
• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to processing based on legitimate interests or to direct marketing;
• withdraw consent at any time where processing is based on consent;
• request data portability where the right applies;
• ask about safeguards used for certain international transfers;
• not be subject to certain solely automated decisions; and
• complain to an appropriate data protection authority.

These rights are not absolute and may be limited by applicable law. We may need to verify your identity before acting on a request and may retain certain information where legally permitted or required. We will respond within the period required by applicable law.

To exercise a right, email info@earlysmilefoundation.org with the subject line “Privacy Request.” You may also unsubscribe from marketing emails using the link included in those messages.

You may raise a concern with Ghana’s Data Protection Commission. If the GDPR applies to your information, you may also complain to the data protection authority in the EU or EEA country where you live, work, or believe an infringement occurred.

10. Children's Privacy

Supporting children and young people is central to our mission, and we treat their information with particular care. Our general Website is intended for a broad audience and is not designed to invite children to submit personal information independently where parental or guardian involvement is legally required.

When we collect information about a child for a program, event, story, photograph, video, or safeguarding purpose, we aim to:

• collect only information that is necessary and appropriate;
• provide age-appropriate information about how the data will be used;
• obtain consent or authorization from a parent or legal guardian where required;
• consider the child’s views and best interests;
• limit access and sharing, particularly for sensitive or safeguarding information; and
• avoid publishing information that creates an unnecessary risk of identifying, locating, or harming a child.

If you believe that a child has provided information to us without appropriate authorization, please contact us so that we can review and, where appropriate, delete or restrict that information.

11. Contact Information

For questions, concerns, complaints, or requests relating to this Privacy Policy or our handling of personal information, contact:

Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our activities, services, technology, or legal obligations. We will post the revised policy on this page and update the “last updated” date above. If a change materially affects how we use information already collected, we will provide additional notice or seek consent where required.