Website privacy notice
Updated 22nd March 2019
Rwanda Action is a charity and a company limited by guarantee registered in England and Wales with charity number 1124634 and company number 06610865.
We take the privacy and security of our supporters, volunteers, beneficiaries and staff very seriously, making every reasonable effort to ensure that your personal data is kept secure and intact. This policy has been put in place to protect your rights under the Data Protection Regulations, and it is important that you understand what we will do with your data and are happy with this. It describes how Rwanda Action collects, stores and uses your personal data, together with our obligations, your rights, and how individual personal preferences can be amended.
If you want to discuss any matter relating to how your data is used, including amending your personal preferences, please email us at firstname.lastname@example.org or write to us at Rwanda Action, The Old Cottage, Peasmarsh, East Sussex, TN31 6TB. We may be required in certain instances to ask that your request for information be submitted in writing.
We may change this policy from time to time and any such changes will be published online at www.rwanda-aid.org. Notwithstanding any change to this policy, we will continue to process your personal data in accordance with your rights and our obligations in law.
This policy is effective from 19 October 2018.
WHAT DATA DO WE COLLECT ABOUT YOU, WHY AND HOW DO WE USE IT?
Organisations are permitted to process data if they have one or more legal bases for doing so. Personal data means any information capable of identifying an individual. It does not include anonymised data.
Please note that by providing us with your data, you warrant to us that you are over 13 years of age.
We may collect and use the following personal data about you:
Where appropriate and with your knowledge and consent, we will collect data necessary to ensure the safeguarding of children and vulnerable persons, such as that required to undertake a Disclosure and Barring Service criminal records check.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver craft items you) but we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing, including requesting your consent if necessary.
We may process your personal data without your knowledge or consent where this is required or permitted by law, but will only do so in accordance with this policy.
We do not carry out automated decision making or any type of automated profiling.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect data about you either when you provide it directly to us (by phone, post or email), including when you enquire about our activities such as fundraising or volunteering, or when you subscribe to our newsletter via the website, send or receive an email or make a donation or purchase products to or from us.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
We will only ever collect the information that we need, including data that will be useful to help fulfil our charitable objectives or improve our services. The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our sites.
NEWSLETTERS AND OTHER MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you our newsletter and other marketing communications is legitimate interest, but certain forms of communication (specifically email and texts, but not post or non-automated phone calls) require consent which we will collect where necessary. You can update your preferences at any time either by contacting us directly at email@example.com or by using the unsubscribe option in every newsletter.
Opting out of receiving our newsletter/marketing communications whether by email, text or other means does not remove you from our database and will not affect the data we hold relating to other forms of engagement that you have had with us, including purchases, volunteering or donations. You may request deletion of your data at any time in writing, subject to any overriding legal requirement for its retention, such as the need, where appropriate, to comply with the requirements of Her Majesty’s Revenue and Customs or other regulatory authorities, or to prevent the commission of or assist in the investigation of an actual or suspected criminal offence. We may keep certain data on a ‘suppression list’ so we know, if requested, not to contact you or process your data in future until further notice.
DISCLOSURES OF YOUR PERSONAL DATA
We may in certain sometimes share your personal data with trusted third parties, including with and in the circumstances set out below
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. Except as stated above, or as otherwise permitted or required by law, we will not share your data with other third parties and will never sell it to anyone.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Our third parties service provider (Mailchimp) is based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Mailchimp are a US-based provider that is part of EU-US Privacy Shield: this means we may transfer data to them, as they have equivalent safeguards in place.
We may use other extra-territorial service providers for Cloud storage or the secure storage of data, but only if they too have in place stringent safeguards that meet the standards required by UK law.
Data may be shared with our trusted colleagues and partners in Rwanda, such as that relating to visiting staff or volunteers. Such data is limited to that which is strictly necessary for the purposes for which it is being shared and is deleted or destroyed when no longer required for that purpose. We take appropriate all technical and organisational measures necessary to protect the privacy and security of the individuals and to prevent the unauthorised or unlawful processing, accidental loss or destruction of, or damage to personal data.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees, volunteers and trusted partners and third parties who have a legitimate need to process such data. They will only process your personal data on our instructions and, where appropriate, formal agreements will be put in place to ensure its privacy and security.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to do so.
The transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. Please note that, unless encrypted, email messages sent via the internet may not be secure and could be intercepted and read by someone else. Please bear this in mind when deciding whether to include personal or sensitive information in any email messages you send to us.
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected or being processed, bearing in mind your wishes and any legal, accounting, or reporting requirements. For example, for tax purposes the law requires us to keep basic information about our beneficiaries, supporters and volunteers (including Contact, Identity, Financial and Transaction Data) for six years after they stop supporting us.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
As stated, we may keep certain data on a ‘suppression list’ so we know, if requested, not to contact you or process your data in future until further notice.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can read more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a small fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Where a data request relates to another person, including a child under the age of 16, we will require proof that the person requesting the data has a legal right to receive it on behalf of that other person.
We will respond to all legitimate requests within 30 days, once we have established the identity of the person submitting the request.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
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