Wellspring Association

Integrated Ethics, Safeguarding, GDPR, Website Use & Privacy Policy

Last updated: [29.04.2026)

Wellspring Association (“Wellspring”, “we”, “our”, or “us”) is a registered Non‑Profit Association in Cyprus (Registration No. 4298), based in Limassol. Wellspring is committed to supporting individuals affected by human trafficking, exploitation, abuse, and related vulnerabilities.

This document sets out our commitments to GDPR compliance, safeguarding, ethical conduct, financial transparency, acceptable website use, and accountability.

1. Our Values and Principles

Wellspring operates according to the following principles:

• Respect for dignity, autonomy, and human rights
• Zero tolerance for abuse, exploitation, harassment, or discrimination
• Survivor‑centred, trauma‑informed, and confidential support
• Transparency, integrity, and accountability in all activities

These principles apply to all staff, volunteers, interns, trustees, and partners.

2. GDPR & Privacy Policy (Data Protection)

Wellspring complies fully with the General Data Protection Regulation (EU GDPR 2016/679) and applicable Cyprus data‑protection legislation.

2.1 Personal Data We Collect

We may collect:

• Names, contact details, and communication records
• Information submitted via website forms, email, or donations
• Limited sensitive data necessary to provide support services

Sensitive personal data is handled with strict confidentiality and care.

2.2 Legal Basis for Processing

We process personal data only where one or more of the following apply:

• Explicit consent of the data subject
• Legitimate interest in delivering charitable services
• Compliance with legal or regulatory obligations

2.3 Use of Personal Data

Personal data is used only for:

• Providing support and services
• Responding to enquiries
• Managing donations and organisational administration
• Legal and safeguarding requirements

2.4 Data Security and Retention

• Data is stored securely and accessed only by authorised persons
• Personal data is retained only for as long as necessary

2.5 Data Subject Rights

Under GDPR, individuals have the right to:

• Access their personal data
• Request correction or deletion
• Restrict or object to processing
• Withdraw consent at any time

Requests should be sent to:
📧 info@wellspringcyprus.com

3. Safeguarding Policy

Wellspring is committed to safeguarding vulnerable adults and at‑risk individuals.

3.1 Our Commitment

• Zero tolerance of abuse, neglect, or exploitation
• Safety, informed consent, and confidentiality are prioritised
• Safeguarding concerns are acted upon promptly and responsibly

3.2 Responsibilities

All representatives must:

• Act in the best interests of service users
• Maintain appropriate professional boundaries
• Report safeguarding concerns through internal procedures

4. Anti‑Trafficking & Exploitation Policy

Wellspring exists to counter human trafficking and exploitation. We commit to:

• Survivor‑centred care and long‑term restoration
• Ethical operations and partnerships
• Raising awareness and prevention initiatives
• Never benefiting directly or indirectly from exploitation

5. Code of Conduct (Staff, Volunteers, Interns)

All representatives of Wellspring must:

• Act professionally, respectfully, and responsibly
• Maintain confidentiality at all times
• Avoid conflicts of interest
• Follow organisational policies and applicable law
• Respect equality, diversity, and human rights

Breaches of this Code may result in disciplinary action, including termination of involvement.

6. Complaints & Feedback Policy

Wellspring welcomes feedback and aims to resolve concerns fairly and transparently.

6.1 Submitting a Complaint

• Complaints may be made via email or in writing
• All complaints are handled confidentially and impartially
• No retaliation will occur against those raising concerns

Complaints should be sent to:
📧 info@wellspringcyprus.com

7. Donations & Financial Transparency Policy

Wellspring commits to responsible and ethical financial management.

• Donations are used solely to support our charitable mission
• Donor information is treated confidentially
• Fundraising is conducted with honesty and transparency

8. Website Terms of Use & Acceptable Use Policy

8.1 Ownership and Intellectual Property

All content on this website, unless otherwise stated, is the property of Wellspring Association and may not be copied or used without permission.

8.2 Website Disclaimer

Website content is provided for general information purposes only and does not constitute professional, medical, legal, or therapeutic advice.

8.3 External Links

Wellspring is not responsible for the content or privacy practices of third‑party websites linked from this site.

8.4 Acceptable Use of the Website

By accessing or using this website, users agree to use it lawfully, respectfully, and in accordance with this policy.

Users must not:

• Use the website for unlawful, harmful, abusive, or misleading purposes
• Submit false, offensive, or inappropriate information
• Attempt to interfere with the website’s security or functionality
• Misuse contact forms or impersonate others

Wellspring reserves the right to restrict or refuse access to the website if misuse is identified.

9. Policy Review

This policy is reviewed periodically to ensure it remains lawful, accurate, and aligned with Wellspring’s mission. Updates will be published on the website.

10. Contact Information

Wellspring Association
📍 Limassol, Cyprus
📄 Registered Non‑Profit Association – Registration No. 4298
📧 info@wellspringcyprus.com