Data Processing Information

Last Updated: January 2025

1. Data Controller

Leaders of Tomorrow (LOT)
Location: Baghdad, Iraq
Email: [email protected]
Program Email: [email protected]

2. Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Consent: When you apply and participate in our program, you provide explicit consent for us to process your data for program purposes.
  • Contractual Necessity: Processing is necessary to fulfill our program services and deliver the 10-week digital exchange experience.
  • Legitimate Interests: We process data to maintain program quality, ensure participant safety, and build our alumni network.
  • Legal Obligations: We may process data to comply with applicable laws and regulations.

3. Categories of Personal Data Processed

3.1 Application Data

  • Personal identification (name, age, date of birth)
  • Contact information (email, phone number)
  • Demographic information (country, time zone)
  • Educational background and qualifications
  • English proficiency assessment
  • Application essays and motivation statements
  • Interview recordings and notes

3.2 Program Participation Data

  • Virtual Host Family assignment and interactions
  • Dialogue Session attendance and participation
  • Video Call attendance records
  • Discord channel activity and communications
  • Cultural exchange submissions (music, food, traditions)
  • Project planning documents and collaborations
  • Performance assessments and feedback

3.3 Technical Data

  • IP addresses and device identifiers
  • Browser and device information
  • Platform usage statistics (Discord, Google Meet)
  • Cookies and tracking data

4. Processing Purposes

We process your data for the following specific purposes:

  • Application Evaluation: To assess eligibility and select participants for the Finalist Stage
  • Program Delivery: To organize Virtual Host Families, schedule sessions, and facilitate program activities
  • Communication: To send program updates, reminders, and important announcements
  • Attendance Tracking: To monitor participation and determine eligibility for Certificates of Distinguished Achievement
  • Community Building: To facilitate connections between participants from diverse backgrounds
  • Quality Assurance: To evaluate program effectiveness and improve our services
  • Alumni Network: To maintain connections with program graduates and facilitate ongoing engagement
  • Mini-Grant Evaluation: To assess applications for post-program funding opportunities
  • Safety and Compliance: To ensure a safe environment and comply with our zero-tolerance policies

5. Data Recipients

Your data may be shared with:

  • Program Staff: Program Managers, Program Officers, and Facilitators who need access to run the program
  • Virtual Host Family Members: Your Facilitator and fellow participants in your assigned group
  • Service Providers:
    • Discord (for community platform services)
    • Google Meet (for video conferencing)
    • Email service providers
    • Cloud storage providers
  • Legal Authorities: When required by law or to protect participant safety

All service providers are bound by strict confidentiality and data protection agreements.

6. International Data Transfers

As a global program, your data may be transferred to and processed in countries outside your country of residence, including:

  • Iraq (our headquarters in Baghdad)
  • United States (Discord and Google services)
  • Other countries where our service providers operate

We ensure appropriate safeguards are in place, including standard contractual clauses and adequacy decisions, to protect your data during international transfers.

7. Data Retention Periods

  • Application Data: Retained for 2 years after application, or until you request deletion
  • Program Participation Data: Retained for the duration of the program and 3 years thereafter
  • Alumni Information: Retained indefinitely to maintain our global network, unless you request deletion
  • Legal Records: Retained as required by applicable laws

8. Your Rights

You have the right to:

  • Access: Request information about what personal data we hold about you
  • Rectification: Request correction of inaccurate data
  • Erasure: Request deletion of your data (subject to program requirements)
  • Restriction: Request limitation of processing in certain circumstances
  • Data Portability: Receive your data in a structured, machine-readable format
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw consent at any time (may affect program participation)

To exercise these rights, contact us at [email protected]. We will respond within 30 days.

9. Automated Decision-Making

We do not use fully automated decision-making processes. All application evaluations and program decisions involve human review by our Program Managers and Officers.

10. Data Security Measures

We implement comprehensive security measures including:

  • Encryption of data in transit and at rest
  • Access controls and authentication
  • Regular security assessments
  • Staff training on data protection
  • Secure backup and recovery procedures

11. Contact Information

For questions about data processing or to exercise your rights:

Data Protection Contact:
Email: [email protected]
Program Email: [email protected]
Location: Baghdad, Iraq

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