The Tesfa Sponsorship Trust UK’s Privacy Notice
May 2018
This version adopted 4th September 2018
Scope
This notice supersedes all earlier versions and is designed to meet the requirements of the General Data Protection Regulation (GDPR), the Privacy and Electronic Communications Regulations (PECR) and any legacy data concerning the Data Protection Act. These combined rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.
Who We Are
The Tesfa Sponsorship Trust UK (‘Tesfa Trust’) is a registered UK charity (charity number: 1177205), registered in England at 3 Bryant Way, Toddington, Beds, LU5 6EX. Tesfa Trust’s mission statement, as shown on our Trust Deed, is ‘The prevention or relief of poverty in Addis Ababa, Ethiopia by providing: grants, items and services to individuals in need and/or charities, or other organisations working to prevent or relieve poverty.’ We currently put this into practice through partnership with two community-run NGOs in Addis Ababa, where we facilitate the sponsorship of children and elderly.
For the purposes of the General Data Protection Regulation 2018 (GDPR) we are the Data Controller, and when carrying out certain contractual responsibilities on behalf of third parties, the data processor.
Personal Data
Tesfa Trust (hereafter TT) will collect and store personal data which you provide us with in order to fulfil our contractual obligations for a booking or service you have purchased from us, or to contact you with regards to employment or manage your data if you are an existing employee. If you give consent, we will also communicate with you our news, special offers, competitions and other content where you have expressed an interest, using your chosen method(s) of opt-in contact.
For the purposes of marketing, TT will collect and store your basic personal data which you have provided, to make contact regarding the information you have requested using the methods you have agreed. This information will be retained to allow us to maintain ongoing contact and to promote the legitimate marketing interests of TT. Your marketing data will be kept with us until you notify us that you either no longer wish to receive information, or you request that your information is erased. You can request to no longer receive information from us at any time, either via phone, by email or on our website (see the end of this Privacy Notice).
TT uses the Google infrastructure for secure storage and email services. Any website analytics processed by Google may be held outside the EEA in accordance with the EU-US Privacy Shield. Our website is hosted by WordPress.com (https://automattic.com/privacy/). TT also uses Slack for internal communications (https://slack.com/privacy-policy). By submitting your personal data, you consent to this retention and processing.
TT does not broker or share your data with third parties unless this is needed to fulfil our legal, contractual and/or marketing fulfilment. We will not collect any personal data from you that we do not need in order to provide or manage the services outlined. At all times TT will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with GDPR and other data protection legislation.
The information we collect
TT receives and stores information you enter on our website or give us via telephone or email. This includes information that can identify you (“personal information”), and may include your first and last name, telephone number, postal and email addresses. If you enter into correspondence with us regarding an enquiry or complaint, we may also keep details of that correspondence. You can choose not to provide information to us, but in general some information about you is required in order for you to register an account; participate in a survey, competition or promotion, sign up for a newsletter, apply for a job or ask us a question
IP addresses
We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns which does not identify any individual.
COOKIES
What is a cookie?
A cookie is a small plain text file used to store information relating to a visit to a website or an opened email campaign. 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 such as an email marketing campaign. These files can be used to personalise and improve your digital and marketing related experiences.
Which cookies do we use and what do we do with them?
We use cookies on our websites and in our email campaigns to monitor how well they are working and to continually improve the experience for our users. The use of identify cookies by TT may include:
- authentication – to identify you when you visit and navigate our website
- status – to help us to determine if you are logged into our website
- shopping cart – to manage the state of your shopping cart as you navigate our website
- personalisation – to store information about your preferences and to personalise your website viewing
- security – as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
- advertising – to help us to display advertisements that will be relevant to you
- analysis – to help us to analyse the use and performance of our website and services
- cookie consent – for storing your preferences in relation to the general use of cookies
Additionally, you can opt in or out to us using the following cookies:
Website content – TT may personalise content so your digital viewing experience is more relevant, based on your previous page views or Google searches.
Advertising – you may see personalised TT adverts on other websites. In order for these to work, third-party providers may use software which adds a cookie to your browser. This cookie enables us to serve the advert to you, let us know if you’ve seen it and if you then go on to make a purchase from our site. No personally identifiable information is held.
Emails – these cookies are used on our marketing emails to monitor the effectiveness of our campaigns and help us deliver more of the content that our supporters find interesting.
When you open an email our software shows us information such as the number of times you have read the email and the links you have clicked. Tracking is only used on marketing emails and not email communications with TT staff.
Third party cookies
The TT website may use third party embedded content from providers such as Facebook, YouTube and Google. Cookies may be set by these sites in order for this functionality to work, however these are not managed by TT and data collected from them may be stored outside the EEA.
You can find out more about our third parties’ privacy policies by using the links below:
Facebook: https://en-gb.facebook.com/policy.php
Google and YouTube: https://www.google.com/intl/en/policies/privacy
Google Analytics
TT uses Google Analytics to scrutinise its website. The information Google Analytics gatherers using cookies relating to our website, is used to create generic reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/
Google AdSense
In the future, TT may publish Google AdSense advertisements on our website. To determine your interests, Google tracks your website behaviour and on other sites using cookies. This behaviour tracking allows Google to tailor the advertisements you see on other websites to reflect your interests (please note TT will not publish interest-based advertisements on its own website).
You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. Please note that these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996
Controlling cookies
There are various ways that you can manage cookies, the majority of web browsers will allow you to disable the cookies you don’t want. Please be aware that changing your cookie settings will affect all websites you visit unless you specify otherwise. Disabling cookies may also affect your browsing experience as some website functionality, such as logging in, will not work without them.
Please see below for more details on changing your settings on the most popular web browsers:
Internet Explorer https://support.microsoft.com/en-us/help/17479/windows-internet-explorer-11-change-securityprivacy-settings
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Safari: https://www.apple.com/legal/privacy/en-ww/
SOCIAL MEDIA
Social Media Services
You can choose to access certain third party social media websites and services (such as Facebook and Twitter) through our site. When you do so, you are sharing information with those sites and the information you share will be governed by their privacy policies (including that the site may share information with us). You may be able to modify your privacy settings with these third party social media websites. Please refer to the relevant provider policies for more information.
The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if you refuse to accept cookies from TT, you may not be able to access portions of our site.
External links and social plug-ins
If any part of the TT website links you to other websites, those websites do not operate under this Privacy Notice. TT recommends that you examine the privacy policies posted on these other websites to understand their procedures for collecting, using, and disclosing personal information.
USING YOUR INFORMATION
How we use your information
We use information about you for the following general purposes: to provide you with the products and services you request; to provide you with updates; to manage your account, including processing sponsorship payments; to communicate with you in general; to respond to your questions and comments; to allow us to contact you for customer service, if necessary; to measure interest in and improve our products, services, and website; to resolve disputes, collect fees, or troubleshoot problems; to prevent potentially prohibited or illegal activities; to enforce our Terms of Use; and as otherwise described to you at the point of collection.
Additionally, at the point of your data collection, you can now opt in, enabling us to notify you by email, post or phone about special offers and services that may be of interest to you, customise your experience with TT; to reward you as part of any reward and recognition programme you choose to join and to solicit with your permission other information from you.
Email communications
We want to make it easy for you to take advantage of any opportunities or events we advertise on our website. One way we do this is by sending you email messages that relate to an interest you’ve shown historically. For example, we may send you an email or contact you if you have attempted to register as a sponsor. Please note that you will have the opportunity to choose not to receive these email messages in any such email we send. Alongside our Google-hosted email service, we may use Mailchimp (https://mailchimp.com/legal/privacy/) for certain forms of email communication.
We also may share your information
When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of TT, the website or users of the website; and in connection with our Terms of Use and other agreements. In connection with a corporate transaction, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Unsubscribing from marketing activities
For the purposes of marketing, TT is relying on consent and/or legitimate interest. You can exercise your right to change your preferences at any time to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right to unsubscribe from these activities at any time by contacting us via phone, email, the website, or by clicking ‘unsubscribe’ in the footer of any of our emails.
Updates to our privacy notice
We may update this privacy notice from time to time, each version is dated to enable you to identify the latest version. Your continued use of this site will constitute your agreement to any changes we may make. If you have opted in to receive marketing communications, you will be emailed a copy if we update our privacy notice.
Data security
We make it a high priority to ensure the security and confidentiality of the personal information you provide to us. All information you provide TT is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. You can change your password if you believe that your personal security may have been compromised.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
DATA SUBJECT RIGHTS
Your rights as a data subject
At any point whilst TT is in possession of or processing your personal data, all data subjects, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
In the event that TT refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
TT, at your request, can confirm what information it holds about you and how it is processed.
You can request the following information:
- Identity and the contact details of the person or organisation (TT) that has determined how and why to process your data
- Contact details of the data protection officer, where applicable
- The purpose of the processing as well as the legal basis for processing
- If the processing is based on the legitimate interests of TT and more information about those interests
- The categories of personal data collected, stored and processed
- Recipient(s) or categories of recipients that the data is/will be disclosed to
- How long the data will be stored
- Details of your rights to correct, erase, restrict or object to such processing
- Information about your right to withdraw consent at any time
- How to lodge a complaint with the supervisory authority (ICO)
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data
- The source of personal data if it wasn’t collected directly from you
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing
To access what personal data is held, identification will be required TT will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If TT is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to contact@tesfa-trust.org, phoning 07968 505859 or writing to us at the address further below.
COMPLIANCE
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by TT or its data processors, you have the right to complain to TT. If you do not get a response within 30 days you can complain to the ICO.
Contact details are as follows:
The Tesfa Trust,
FAO The Data Protection Officer
3 Bryant Way
Toddington
Beds
LU5 6EX
Tel: 07968 505859
email: contact@tesfa-trust.org
Information Commissioner’s Office
Wycliffe House,
Water Lane,
Wilmslow,
SK9 5AF
The Tesfa Sponsorship Trust UK 