This privacy statement describes how North Africa Media Academy
(NAMA) collects and uses the personal information you provide on our
website. For these purposes, NAMA is the data controller of any personal
data we collect. NAMA (registered in Tunisia under decree-law number
88- 2011) (“NAMA” ,“we”, “us”, “our”) is committed to protecting your
At all times, we aim to respect any personal information you share
with us or that we receive from other organizations, and keep it safe.
This Privacy Notice (“Notice”) sets out our data processing practices
and your rights and options regarding the ways in which your personal
information is collected (including through our website www.na-ma.org)
This Notice contains important information about your personal rights
to privacy. Please read it carefully to understand how we use your
personal information. The provision of your personal information to us
is voluntary. However, without providing us with your personal
information, your use of our services or your interaction with us may be
impaired. For example, you will be unable to sign up for training or to
receive our email newsletter.
- We collect personal information about you
- What personal information do we use?
- How and why will we use your personal information?
- Lawful bases
- Communications for marketing
- Children’s personal information
- How long do we keep your personal information?
- Will we share your personal information?
- Security/storage of and access to your personal information
- International Data Transfers
- Exercising your rights
- Changes to this Notice
- Links and third parties
- How to contact us
a. When you give it to us directly
For example, personal information that you submit through our website by signing up for our email newsletter or to register for training, e-learning or our competitions, or personal information that you give to us when you communicate with us by email, phone or letter.
b. When we obtain it indirectly
For example, your personal information may be shared with us by third parties including, for example, our business partners; sub-contractors in technical, payment and delivery services; analytics providers and search information providers. To the extent we have not done so already, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.
c. When it is available publicly
Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services (for example when you choose to interact with us through platforms such as Facebook, Instagram or Twitter).
d. When you visit our website
When you visit our website, we automatically collect the following types of personal information:
- Technical information, like browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
- Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
We may collect, store and otherwise process the following kinds of personal information: Your name and contact details (including emergency contacts), including postal address, telephone number, email address and, where applicable, passport and social media identity; Your date of birth and gender; Your financial information, such as bank details and/or credit/debit card details, account holder name, sort code and account number; Information about your computer/mobile device and your visits to and use of this website, including, for example, your geographical location; Details of your qualifications/experience; Information about our services which you use/which we consider may be of interest to you; and/or Any other personal information which you choose to share with us as per Section 1. Do we process special categories of data? The EU General Data Protection Regulation (“GDPR”) recognizes certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and political opinions. In certain situations, NAMA may collect and/or use these special categories of data (for example, we may need to know details of your medical conditions so that we can make reasonable adjustments to ensure equal access to our training courses.). We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.
Your personal information, however provided to us, will be used for the purposes specified in this Notice. In particular, we may use your personal information: To register you for our training courses and administer your participation; To allow you to take our e-learning courses; To allow you to enter our competitions; To otherwise provide you with services, products or information you have requested; To provide further information about our work, services, activities or products (where necessary, only where you have provided your consent to receive such information); To process your payments; To answer your questions/requests and communicate with you in general; To further our charitable aims in general, including to promote inclusivity in journalism and communications; To analyze and improve our work, services, activities, products or information (including our website), or for our internal records; To report on the impact and effectiveness of our work; To run/administer our website, keep it safe and secure and ensure that content is presented in the most effective manner for you and for your device; To register, administer and personalize online accounts; To register and administer your participation in events; For purposes of publicity; To audit and/or administer our accounts; To satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering); For the prevention of fraud or misuse of services; and/or For the establishment, defense and/or enforcement of legal claims.
The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant: Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you marketing or promotional material by email, and we may ask for your explicit consent to collect special categories of your personal information). Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services). Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, where you pay to attend for one of our training or e-learning courses). Where it is in your/someone else’s vital interests (for example, in case of medical emergency suffered by an individual). Where there is a legitimate interest in us doing so. The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact on your rights). In broad terms, our “legitimate interests” means the interests of running NAMA as a charitable entity and pursuing our aims and ideals; for example improving standards of journalistic and communications training, providing skills-intensive training and improving audience engagement with different media. When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
We may use your contact details to provide you with information about our work, events, services and/or products which we consider may be of interest to you (for example, about services you previously used, or updates about fundraising appeals and/or volunteering opportunities via our newsletter).
Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless allowed to do so via applicable law).
Where you have provided us with your consent previously but do not wish to be contacted by us about our projects and/or services in the future, please let us know by email at email@example.com. You can opt out of receiving emails from NAMA at any time by clicking the “unsubscribe” link at the bottom of our emails.
When we process children’s personal information, where required we will not do so without their consent or, where required, the consent of a parent/guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care.
In general, unless still required in connection with the purpose(s)
for which it was collected and/or processed, we remove your personal
information from our records six years after the date it was collected.
However, if before that date (i) your personal information is no longer
required in connection with such purpose(s), (ii) we are no longer
lawfully entitled to process it or (iii) you validly exercise your right
of erasure (please see Section 11 below), we will remove it from our
records at the relevant time.
If you request to receive no further contact from us, we will keep
some basic information about you on our suppression list in order to
comply with your request and avoid sending you unwanted materials in the
We do not sell or rent your personal information to third parties for
marketing purposes. However, in general we may disclose your personal
information to selected third parties in order to achieve the purposes
set out in this Notice.
Non-exhaustively, those parties may include:
Suppliers and sub-contractors for the performance of any contract we
enter into with them, for example IT service providers such as website
hosts or cloud storage providers;
Governments and entities in overseas countries if you are a consultant travelling to such place to provide training;
Professional service providers such as accountants and lawyers;
Parties assisting us with research to monitor the impact/effectiveness of our services;
Regulatory authorities, such as tax authorities; and/or
Analytics and search engine providers.
In particular, we reserve the right to disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which
case we will disclose your personal information to the (prospective)
seller or buyer of such business or assets;
If substantially all of our assets are acquired by a third party,
personal information held by us may be one of the transferred assets;
If we are under any legal or regulatory duty to do so; and/or
To protect the rights, property or safety of NAMA, its personnel, users, visitors or others.
NAMA is committed to keeping your personal information safe and secure
and we have appropriate and proportionate security policies and
organisational and technical measures in place to help protect your
information. Your personal information is only accessible by
appropriately trained staff, volunteers and contractors, and stored on
secure servers with features enacted to prevent unauthorised access.
Given the nature of our work, we are involved in the transfer of
personal information to countries outside Germany and the European
Economic Area (“EEA”). This may be because we use agencies and/or
suppliers to process personal information on our behalf and they will
transfer and store personal information in a location outside the EEA,
for example the United States. Or it is because you are a consultant
travelling overseas on an assignment which requires us to transfer your
personal information to a Government or entity based in that location
(e.g. providing your passport details).
Please note that some countries outside of Germany and the EEA have a
lower standard of protection for personal information, including lower
security requirements and fewer rights for individuals. Where your
personal information is transferred, stored and/or otherwise processed
outside the EEA in a country that does not offer an equivalent standard
of protection to the EEA, we will take all reasonable steps as far as
possible to ensure that the recipient implements appropriate safeguards
(such as by entering into European Commission-approved model contractual
clauses) designed to protect your personal information and to ensure
that your personal information is treated securely and in accordance
with this Notice. We may obtain your explicit consent to such transfers
or, given that the transfer in these circumstances is limited in scope,
is not repetitive and is necessary for compelling legitimate interests
not overridden by your rights (since you voluntarily agree to be a
consultant on an assignment), we may proceed with the transfer having
considered all the circumstances surrounding the transfer and taken
If you have any questions about the transfer of your personal information, please contact us using the details below.
Unfortunately, no transmission of your personal information over the
internet can be guaranteed to be 100% secure – however, once we have
received your personal information, we will use strict procedures and
security features to try and prevent unauthorised access.
Where we rely on your consent to use your personal information, you
have the right to withdraw that consent at any time. This includes the
right to ask us to stop using your personal information for marketing or
fundraising purposes or to unsubscribe from our email list at any time.
You also have the following rights:
Right of access – you can write to us to ask for confirmation of
what personal information we hold on you and to request a copy of that
personal information. Provided we are satisfied that you are entitled to
see the personal information requested and we have successfully
confirmed your identity, we will provide you with your personal
information subject to any exemptions that apply.
Right of erasure – at your request we will delete your personal
information from our records as far as we are required to do so. In many
cases we will propose to suppress further communications with you,
rather than delete it.
Right of rectification – if you believe our records of your personal
information are inaccurate, you have the right to ask for those records
to be updated. You can also ask us to check the personal information we
hold about you if you are unsure whether it is accurate/up to date.
Right to restrict processing – you have the right to ask for
processing of your personal information to be restricted if there is
disagreement about its accuracy or legitimate usage.
Right to object – you have the right to object to processing where
we are (i) processing your personal information on the basis of the
legitimate interests ground, (ii) using your personal information for
direct marketing or (iii) using your information for statistical
Right to data portability – to the extent required by the GDPR,
where we are processing your personal information (that you have
provided to us) either (i) by relying on your consent or (ii) because
such processing is necessary for the performance of a contract to which
you are party or to take steps at your request prior to entering into a
contact, and in either case we are processing using automated means
(i.e. with no human involvement), you may ask us to provide the personal
information to you – or another service provider – in a
Rights related to automated decision-making – you have the right not
to be subject to a decision based solely on automated processing of
your personal information which produces legal effects on you or
similarly significantly affects on you, unless such a decision (i) is
necessary to enter into/perform a contract between you and us/another
organisation; (ii) is authorised by EU or Member State law to which NAMA
is subject (as long as that law offers you sufficient protection); or
(iii) is based on your explicit consent.
We may ask you for additional information to confirm your identity
and for security purposes, before disclosing personal information
requested to you. Please note that some of these rights only apply in
limited circumstances. For more information, we suggest that you contact
us using the details in section 14 below.
You are further entitled to make a complaint about us or the way we
have processed your personal information to the data protection
supervisory authority in your home country. In Germany, the data
protection authority is the Bundesbeauftragte für Datenschutz und Informationsfreiheit, Email: firstname.lastname@example.org. For further information on how to exercise this right, please contact us using the details in section 14 below.
We may update this Notice from time to time. We will notify you of
significant changes by contacting you directly where reasonably possible
for us to do so and by placing an update notice on our website. This
Notice was last updated on 18th of June 2018.
We link our website directly to other sites. This Notice does not cover
external websites and we are not responsible for the privacy practices
or content of those sites. We encourage you to read the privacy notices
of any external websites you visit via links on our website.
Please let us know if you have any questions or concerns about this
Notice or about the way in which NAMA processes your personal
information by contacting us at our social media channels, or on the