Privacy Policy

Palace for Life Foundation – Data Protection Policy

Effective from: 25 May 2018

Contents:

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary

Introduction

Welcome to the Palace for Life Foundation’s privacy notice. This Privacy Policy will become effective on 25 May 2018.

Palace for Life Foundation respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Palace for Life Foundation collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Palace for Life Foundation is the controller and responsible for your personal data (collectively referred to as Palace for Life, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Palace for Life Foundation, Selhurst Park, London, SE25 6PU

Business Support Manager: Duncan Robinson

Email address: details@palaceforlife.org

Telephone number: 020 8768 6047

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 1st May 2018.

The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes your billing address, delivery address, email address and telephone numbers.
  • Financial Data includes your bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may, where relevant and appropriate, collect Special Data about you, this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, information about your health, genetic and biometric data and details of criminal convictions.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or to receive donations from you). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Special Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • support us by making a donation, volunteering, engaging with fundraising activities on our behalf, booking on one of our programmes or purchasing a product or donation from our website;
    • register to receive updates on our work and activities;
    • register as a participant in one of our programmes designed to support young people in their health, education, safety and wellbeing, or contact us for support and guidance in relation to our work and activities;
    • share your success story;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.

When you provide us with Special Data as a participant of one of our programmes, we keep this separately on our Content Management System (CMS), and only allow relevant persons to access the information for appropriate purposes.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • analytics providers
      • advertising networks; and
      • search information providers.
  • Identity, Contact and Special Data contained and accessible on third party monitoring and reporting systems for the administration and provision of our services. For example, data may be collected this way to administer our health initiatives or programmes targeted at vulnerable young adults and children.
  • Identity, Contact, and Financial and Transaction Data from providers of technical, payment and delivery services. For example, your information may be shared with us this way from third party organisations and fundraising platforms. This will only be done where you have given your consent to help the Palace for Life Foundation in this way.
  • Identity and Contact Data from publicly availably sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to process any donations we receive from you.
  • To provide you with updates and information relating to our work and activities with your permission.
  • To organise and administer fundraising activities.
  • For administrative purposes (i.e. to provide you with information about any of our events you have signed up to).
  • Where it is necessary for our legitimate needs (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where it is carried out in the course of our legitimate activities as a not for profit foundation.
  • Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on your consent only as the basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate needs are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Our basis for processing your data
To register you as a supporter of the Palace for Life Foundation ·         Identity Contact (a) With your permission; or

(b) for our legitimate needs

To provide you with updates on our work and activities ·         Identity

·         Contact

·         Marketing and Communications

(a) With your permission; and/or

(b) for our legitimate needs

To facilitate your volunteer work for our Foundation or engagement with our fundraising activities ·         Identity

·         Contact

·         Special data

·         Financial

·         Transaction

·         Marketing and Communications

(a) With your permission; and/or

(b) for our legitimate needs and activities

To provide support services to you as a participant on one of our programmes, or a receiver of targeted intervention from us ·         Identity

·         Contact

·         Special data

(a) With your permission; and/or

(b) for our legitimate needs and activities

To process and receive donations and fundraising from you:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

·         Identity

·         Contact

·         Financial

·         Transaction

·         Marketing and Communications

(a) With your permission; and/or

(b) for our legitimate needs

To process and deliver your orders of products, services and from our website and your registration to any of our paid programmes or events ·         Identity

·         Contact

·         Financial

·         Transaction

·         Marketing and Communications

(a) To perform a contract with you;

(b) with your permission; and/or

(c) for our legitimate needs

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

·         Identity

·         Contact

·         Profile

·         Marketing and Communications

(a) For our legitimate needs; and/or(b) as required by law

 

To enable you to take part in a prize draw, competition or complete a survey ·         Identity

·         Contact

·         Profile

·         Usage

·         Marketing and Communications

(a) With your permission;

(b) to perform a contract with you; and/or

(c)for our legitimate needs

To administer and protect our charity and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) ·         Identity

·         Contact

·         Technical

(a) For our legitimate needs; and/or

(b) as required by law

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you ·         Identity

·         Contact

·         Profile

·         Usage

·         Marketing and Communications

·         Technical

(a) With your permission; and/or

(b) For our legitimate needs

To use data analytics to improve our website, work, programmes, services, marketing, customer relationships and experiences ·         Technical

·         Usage

For our legitimate needs
To make suggestions and recommendations to you about events, projects or services that may be of interest to you ·         Identity

·         Contact

·         Technical

·         Usage

·         Profile

(a) For our legitimate needs; and/or

(b) with your permission

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, and therefore we will only contact you for marketing purposes with your express permission. To make sure what can choose your marketing preferences, we have established the following personal data control mechanisms:

  • You can let us know that you do not wish to receive our marketing emails by clicking the ‘unsubscribe’ link at the end of our marketing emails;

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, supported us by donating to our causes, taken part in our fundraising activities or volunteering, or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Palace for Life Foundation for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing and/or registering for any of our services or events, participating on our programmes or, entering our promotions or providing us with feedback.

We may still need to contact you for administrative purposes from time to time after you have opted out of receiving marketing messages. This may be in order to process your donation, provide you with information about an event you have signed up to, or give you an explanation or apology in relation to a complaint that you have made.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Specific third parties acting as processors.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our charity or our assets. Alternatively, we may seek to acquire other businesses or charities or merge with them. If a change happens to our charity, then the new Data Controllers may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only keep your personal data for as long as is reasonable or necessary by law.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the link below to find out more about these rights:

Individual Rights

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Needs means the interest of our charity in conducting and managing our charity to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate needs. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate needs against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors who provide IT, system administration services and content and customer relationship management systems.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate need (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.