WAITING FOR APPROVAL BY OUR LEGAL COUNCELLOR

PRIVACY POLICY

We care about the interests of our private donors and other people interested in our organization. Therefore, we have a privacy policy which explains when and why we collect personal information about people who visit our website or donate, how we use it, the conditions under which we may disclose it to others and how we keep it secure. You can find our privacy policy here:

At Favela Painting, we’re committed to protecting and respecting your privacy. This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By
using our website, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to info@favelapainting.com or by writing to:

Favela Painting Foundation
P.O. Box 17196
1001 JD, Amsterdam
The Netherlands

WHO ARE WE?

We are Favela Painting, a Dutch foundation that believes that art is an unique messenger, crossing borders and building bridges and if
implemented in an intelligent way it can be powerful weapon to catalyze social change. We are dedicated to explore the best practise in order to set the standard in the world of community painting. Favela Painting is a registered charity (chamber of commerce number: 34285358). The registered address is:

P.O. Box 17196
1001 JD, Amsterdam
The Netherlands.

HOW DO WE COLLECT INFORMATION?

We obtain information about you when you use our website, for example, when you contact us, when you make a donation or if you
register to receive one of our monthly newsletters.

WHAT TYPE OF INFORMATION IS COLLECTED?

The personal information we collect might include your name, address, email address, IP address, and information regarding what
pages are accessed and when. If you make a donation, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions, as explained below.

HOW DO WE USE YOUR INFORMATION?

We may use your information to:

- process a donation that you have made;
- to carry out our obligations arising from any contracts entered into by you and us;
- seek your views or comments on the work we deliver;
- send you communications which you have requested and that may be of interest to you. These may include information
about campaigns, appeals, other fundraising activities, promotions of our associated companies goods and services;
- process a grant or job application.

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations.. We will hold your personal information on our systems for as long as is necessary for the relevant activity or as long as set out in any relevant contract you hold with us.

WHO HAS ACCES TO YOUR INFORMATION?

We will not sell or rent your information to third parties, nor will we share your information with third parties for marketing purposes.
Third Party Service Providers working on our behalf: We may pass your information to our third party service providers, agents
subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for
example to process donations and send you mailings). However, when we use third party service providers, we disclose only the
personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information
secure and not to use it for their own direct marketing purposes.

Please be reassured that we will not release your information to third parties beyond the Favela Painting network for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party
or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to
comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our supporters and customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

YOUR CHOICES

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct communications from us about the work we do, you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not
contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your
preferences at any time by contacting us by email: info@favelapainting.com

HOW TO ACCES AND UPDATE
YOUR INFORMATION

The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or any of the other information we hold is inaccurate
or out of date, please email us at:
info@favelapainting.com

or write to us at:
P.O. Box 17196
1001 JD, Amsterdam
The Netherlands.

You have the right to ask for a copy of the information Favela Painting holds about you. We may charge you a small fee for information requests to cover our costs in providing you with details of the information we hold about you.

SECURITY PRECAUTIONS

We have Security precautions in place to protect the loss, misuse or alteration of your information. When you give us personal information, we take steps to ensure that it’s treated securely. Any sensitive information (such as credit o debit card details) is encrypted and protected. When you are on a secure page, a lock icon will appear on the bottom of web browser such as Microsoft Internet Explorer. Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we
encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and
practices of other sites even if you access them using links from our website. In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

16 OR UNDER?

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.

TRANSFER OF INFORMATION
OUTSIDE OF EUROPE

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries
outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the Netherlands. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

REVIEW OF THIS POLICY

We keep this Policy under regular review. This Policy was last updated in February 2018.

WAITING FOR APPROVAL BY OUR LEGAL COUNCELLOR

WHISTLEBLOWER POLICY

The Favela Painting Foundation requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Favela Painting Foundation, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

REPORTING RESPONSIBILITY

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concern internally so that Favela Painting can address and correct inappropriate conduct and actions. It is the responsibility of all board members, employees and volunteers to report concerns about violations of Favela Painting’s code of ethics or suspected violations of law or regulations that govern Favela Painting’s operations.

NO RETALIATION

It is contrary to the values of Favela Painting for anyone to retaliate against any board member, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Favela Painting. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

REPORTING PROCEDURE

Favela Painting has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Executive Director, or a board member. Supervisors and managers are required to report complaints or concerns about suspected
ethical and legal violations in writing to the Favela Painting Foundation. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Executive Director.

COMPLIANCE OFFICER

Favela Painting is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the Executive Director and the Board of Directors of all complaints and their resolution and will report at least annually to the Treasurer/Chair of the Finance Committee/Audit Committee on compliance activity relating to accounting or alleged financial improprieties.

ACCOUNTING AND AUDITING MATTERS

Favela Painting shall immediately notify the Audit Committee/Finance Committee of any concerns or complaint
regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

CONFIDENTIALITY

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible,
consistent with the need to conduct an adequate investigation.

HANDLING OF REPORTED VIOLATIONS

Favela Painting will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Policy approved by the Board of Directors on 20-02-2018.