Privacy and cookies policy

  1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2    We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.3    This privacy policy was last updated on 8th February 2019

  1. Credit

2.1    This document was created using a template from SEQ Legal (http://www.seqlegal.com).

  1. How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

3.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services

3.3    We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.  The legal basis for this processing is our legitimate interests, namely [the proper administration of our website and business

3.4    We may process your information included in your personal profile on our website ("profile data").  The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business

3.5    We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business

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3.6    We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business

3.7    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent

3.8   We may process [information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users

3.9   We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to rotect your vital interests or the vital interests of another natural person.

3.11  Please do not supply any other person's personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

4.1    We may disclose your personal data to any member of our Trust insofar as reasonably necessary for the purposes set out in this policy.

4.2    We will share limited donor personal data (profile and/or service) to the relevant fundraiser where donations are made, insofar as reasonably necessary to inform them that an associated donation has been made.

4.3    Financial transactions relating to our website and services may be handled by our payment services providers, Go Cardless and Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:

Stripe:https://stripe.com/gb/privacy)

-         GoCardless  (URL https://gocardless.com/legal/privacy/)

 

4.4    Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

  1. Your data will be made available to our website provider
  2. The data that may be available to them include any of the data we collect as described in this policy.
  3. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
  4. They will store your data for a maximum of 7 years.
  5. This processing does not affect your rights as detailed in this privacy policy.

4.5    In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Retaining and deleting personal data

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

  1. Your rights

7.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

7.2    We may withhold personal information that you request to the extent permitted by law.

7.3    You may instruct us at any time not to process your personal information for marketing purposes.

7.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

  1. Third party websites

8.1    Our website includes hyperlinks to, and details of, third party websites.

8.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

8.3   This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them.  If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data

8.4   We operate a number of social media pages (including Facebook, Twitter, and You Tube).  Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information.  Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

  1. About cookies

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that we use

10.1    We use cookies as you navigate our website, to help us to analyse the use and performance of our website and services and for marketing purposes.

  1. Cookies used by our service providers

11.1    Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2    We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. This data may be stored outside the EU, under a EU-US Privacy Shield agreement. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/

  1. Managing cookies

12.1    Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2    Blocking all cookies will have a negative impact upon the usability of many websites.

  1. Complaints

13.1  If you have a complaint about us, or the treatment of your data, you can contact the Charity Commission. The Charity Commission is the independent watchdog for charities.  You can make a complaint about a charity on their website at www.charity-commission.gov.uk.

13.2  If you've got a complaint about our fundraising activities you can also complain to the Fundraising Regulator.  To find out how to go about making a complaint, go to the Fundraising Regulator website at https://www.fundraisingregulator.org.uk/make-a-complaint/complaints/