Transform Trade Privacy and Cookies Policy
Last update: 18/1/2019
Please note: Transform Trade may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from the date shown above.
Introduction
This Privacy Policy sets out how we collect, use and store your personal information (any information that identifies or could identify you).
Our policy may change in accordance with the regulatory environment or to reflect changes within our own organisation. Where we have made any changes to this Privacy Policy, we will make this clear on our website or contact you about any changes.
Transform Trade are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
We are a "data controller" for the purposes of the EU General Data Protection Regulation 2016/679 ("Data Protection Law"). This means that we are responsible for, and control the processing of, your personal information.
For further information about our privacy practices, please contact us using the details supplied at the end of this document.
How we collect information about you
We collect information from you in the following ways:
Directly: When you get in touch with us (general enquiries, donations, campaign actions, job or volunteering opportunities etc) or otherwise provide us with your personal information. This includes when you phone us, visit our website, contact us over social media, email us or get in touch through the post, or in person.
Indirectly: When you interact with us through third parties: This could be if you provide a donation through a third party such as Just Giving, Traidcraft plc or another third party where you have provided your consent for your personal information to be shared with us.
Online: We gather general information which might include which pages you visit most often and which services, events or information are of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use "cookies" to help our site run effectively. There are more details below – see 'Cookies'.
HotJar
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
Information we collect and why we use it
Personal Information
Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number and credit/debit card details (if you are making a purchase or donation), as well as information you provide in any communications between us. You will have given us this information whilst making a donation, registering for an event, taking a campaign action, submitting a form on our website or any of the other ways you may interact with us.
We will mainly use this information:
To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
To provide the services, goods or information you have requested.
To forward to a campaign target or decision-maker as part of a campaign action you have signed up to.
To update you with important administrative messages about your donation, an event or services, goods or information you have requested.
To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations.
To keep a record of your relationship with us.
If you do not provide this information, we will not be able to process your donation, sign you up for a specific event or accurately administer your account.
We may also use your personal information:
To contact you about our work and how you can support Transform Trade (see section on 'Marketing' below for further information).
To invite you to participate in surveys or research.
Sensitive Personal Information
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sexual orientation or religious beliefs.
As we are a Christian charity with many Christian supporters, Transform Trade holds sensitive personal information relating only to our supporters’ religious faith and only when given explicit consent to do so. There is no obligation to provide this information. For those who give permission, we use this information to help us tailor the marketing information we send you to ensure, as far as possible, that it is relevant to you in the context of your religious beliefs.
As part of our lobbying we also hold some sensitive information regarding political beliefs.
We erase any sensitive personal information on faith from our systems automatically after an account is dormant for a period of 36 months.
Additional sensitive information is only held by our HR department in relation to employment/recruitment requirements. Declaration of this information by the individual is not compulsory.
Profiling
We may carry out targeted fundraising activities using profiling techniques based on the information we hold about you. We do this to ensure the information we send is relevant to you in relation to your past support and to ensure we fulfil legitimate interest criteria for sending you marketing information via post and telephone where we do not hold explicit consent to market to you.
We may also work with third party organisations who provide additional insight, this may include providing wealth screening information or general information about you that is publicly available. Wealth screening companies are required to get your explicit consent in order to share it specifically with Transform Trade and we require any third parties we use to prove your consent.
This information can be appended to the information that you have provided. This allows us to use our resources more effectively by better understanding the background of our supporters and making appropriate requests based on what may interest them and their capacity to give.
If you have any concerns about this or wish to change your preferences, please contact us directly (see contact section for more details).
Legal basis for processing your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have made a donation on our website).
Data may also be processed because there is a legitimate interest for Transform Trade to do so.
Whenever we process your Personal Information under the ‘legitimate interest' lawful basis, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance. You can opt out of receiving our information via any or all channels, at any time, using the contact details at the bottom of this policy.
Some examples of where we have a legitimate interest to process your Personal Information are where we contact you about our work via post or telephone, use your personal information for data analytics, conducting research to better understand who our supporters are, improving our services, for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.
Marketing
We will only contact you about our work and how you can support Transform Trade by email or SMS if you have explicitly agreed for us to contact you in this manner.
If you have provided us with your email address or mobile phone number we may use these in order to administer your activity with us without consent as consent is implied.
If you have provided us with your postal address and/or telephone number we may send you information about our work and how you can support Transform Trade via these methods unless you have told us you would prefer not to hear from us in that way (postal/telephone opt-out).
You can update your choices or stop us sending you these communications at any time by emailing us, clicking the unsubscribe link at the bottom of the relevant communication or by submitting requests in writing. See contact section for full details.
Sharing your Information
The personal information we collect about you will mainly be used by our staff (and volunteers) at Transform Trade so that they can support you.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities, nor do we sell any information about your web browsing activity.
Transform Trade may share your information with suppliers who work with us both inside and outside of the EEA (European Economic Area). These suppliers such as Microsoft and Mailchimp either work with us or on our behalf to deliver our services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. Some examples of where we may share your information are with our fulfilment partners who help to create and send information to you (to reduce costs) or with our partners who help us to process donations and claim Gift Aid including HMRC.
We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.
Legal disclosure
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority), or, in order to enforce our conditions of sale and other agreements.
Keeping your information safe
We take looking after your information very seriously. We've implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and offline, from improper access, use, alteration, destruction and loss.
The transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.
Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or websites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites or advertisers.
Any debit or credit card details which we receive on our website are passed securely to Sage Pay our payment processing partner, according to the Payment Card Industry Security Standards.
Information retention
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations (for example, the collection of Gift Aid).
Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, please get in touch (see contact section). You can also make a complaint to the data protection supervisory authority, the Information Commissioner's Office, https://ico.org.uk/
Access to your personal information
You have the right to request access to a copy of the personal information we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing, providing us with evidence of your identity.
Right to object
You can object to our processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
Consent
If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
Rectification
You can ask us to change or complete any inaccurate or incomplete personal information held about you.
Erasure
You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
Portability
You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
Restriction
You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
No automated-decision making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
Cookies
Cookies are small files, usually made up of letters and numbers, downloaded onto your device (computer, mobile phone, tablet etc.) when you visit a website.
They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, can't be used to identify you.
We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you come to our website and also allows us to improve the user experience.
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We use all four categories of cookies:
Strictly necessary cookies are essential for you to move around our website and to use its features.
Performance cookies collect anonymous information about how you use our site, like which pages are visited most.
Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Targeting or advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. As such, if you visit the Transform Trade website you may then be more likely to see adverts about our work on other websites as your browsing suggests that this is an area of interest.
If you have any questions about how we use cookies, please contact us.
Monitoring
Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
To find out more about this policy and how we look after your personal information, contact (see contact section).
Contact
If you require further information, or have a specific request or query, please contact us via one of the following methods:
Email: hello@transform-trade.org
Post: Transform Trade, Transform Trade, 5th Floor, 7 – 15 Pink Lane, Newcastle upon Tyne, NE1 5DW
Telephone: 0191 497 6445