PRIVACY POLICY

Privacy Officer: Sarah Wilson
Contact email: sarah@khula.org.uk

Thank you for providing  KHULA EDUCATION with your contact and personal information. Holding onto your personal information is a serious responsibility and we want you to know that we’re handling it properly and lawfully. This privacy statement explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure. We are committed to fully comply with the requirements of the General Data Protection Regulation brought into effect on 25th May 2018.

General

KHULA EDUCATION (KHULA) is committed to protecting the privacy of our website visitors. This Privacy Policy seeks to help you understand how we collect and process information about you when you visit our website, and how we use such information. For the purposes of EU data protection laws, KHULA EDUCATION (KHULA) is the data controller (i.e. the organisation responsible for, and which controls the processing of, your personal information).

This Privacy Policy applies when you visit this website. Please note that this Privacy Policy applies only to this website and not to any other website that may be linked to it. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

If you have any questions or comments about this Privacy Policy, you can email us at sarah@khula.org.uk or write to us at 26 Gosfield Street, London W1W 6HH

How We Collect, Use, Share and Protect Your Personal Information

We may collect information about you directly whenever you interact with us. For example, when you contact KHULA EDUCATION (KHULA) regarding our activities, register as a supporter, send or receive information, engage with our social media or make a donation to us, you may provide us with your personal information.

We may also receive information about you when you interact with third parties with whom we work. For example, where you’ve made a donation to us through a third-party website (e.g., Just Giving or Worldpay) and given them permission to share your information with us.

We may supplement what we know about you with information that is available to the public. For example, in order to ensure that our communication with you is relevant and tailored to your background and interests, we may collect information about you from publicly-available sources either directly or through third-party subscription services or service providers. See ‘How will we combine and analyse the information we collect about you?’ for more detail. We may also carry out research using publicly available information to identify individuals who have an affinity to our cause but with whom we are not already in touch.

We may collect aggregated or anonymous information when you visit our website or interact with our content.  For example, we may collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our website or view and interact with our ads and content. Please see our Cookies Policy for more detail.

WHAT INFORMATION DO WE COLLECT?

The information we collect from you directly or from third parties with whom we work, may include:

  • name,
  • address,
  • email address,
  • telephone number,
  • contact preferences,
  • bank account details for setting up a regular direct debit,
  • credit card details for processing credit card payments,
  • employer details for processing a payroll gift,
  • taxpayer status for claiming Gift Aid,
  • date of birth or age to confirm you are over 18,
  • gender, where appropriate (e.g., where registering for an event such as a run or mountain climb).

We do not use cookies to collect this type of information. All online financial transactions will be encrypted using TLS (Transport Layer Security).

We may also collect and process information about your interactions with us, including details about our contacts with you through email, SMS, post, on the phone or in person (i.e., the date, time, and method of contact), details about donations you make to us, events or activities that you register for or attend and any other support you provide to us.

We may also collect and record any other relevant information you share with us about yourself, including your interests or your affiliations with other charities, community groups, your employer or a KHULA EDUCATION (KHULA) partner. If you are a minor, we may collect the name and contact details of a parent or guardian and, where appropriate, the name and location of your school.

In order to ensure that our communication with you is relevant and tailored to your background and interests, we may supplement what we know about you with information that is available to the public.  This allows us to better understand your interests, preferences, and level of potential engagement and/or donation, so that we can contact you in the most appropriate way and to ensure that we do not send you unwanted communications.  The information we collect and process about you from publicly-available sources may include demographic information associated with your postcode or your address and an estimate of your age.  We may collect this information ourselves or through third-party service providers.  For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.

Where we have identified that you may have the capacity or affinity to support KHULA EDUCATION (KHULA) at a higher level, we may use the information we hold about you to identify connections between you and our existing circle of key supporters.  We may review other information about you that is available to the public through internet searches, social networks, such as LinkedIn, subscription services, news archives or public databases (e.g. Companies House, the electoral, political and property registers), such as information about corporate directorships, shareholdings, published biographic information, employment and earnings, philanthropic interests and networks, charitable giving history and motivations and relevant media coverage, so that we can engage with you in a more personalised way.

DO WE PROCESS ‘SENSITIVE’ PERSONAL INFORMATION?

Under data protection law, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs, and political opinions (‘sensitive personal data’).  In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so, such as where we need this information to ensure that we provide appropriate facilities or support to enable you to participate in an athletic event like a marathon.

HOW DO WE USE YOUR INFORMATION?

We may use your information in a number of ways, including:

  • To provide you with information, products or services that you have requested from us or that we feel may be of interest to you;
  • To provide you with information about our work or our activities;
  • To invite you to participate in interactive features on our website;
  • To process donations we may receive from you;
  • To fundraise in accordance with our internal policies and procedures;
  • For administrative purposes (for example, we may contact you regarding an event for which you have registered, to provide information requested or with a query regarding a donation you may have made to us);
  • For internal record keeping relating to any donations, feedback, or complaints;
  • To invite you to participate in voluntary surveys or research;
  • To contact you where you have been identified as a contact person for an organisation, such as a school (if we obtain your contact details in this way, we will only use them to contact you in your capacity as a representative of that organisation unless you have separately indicated that you are happy to be contacted as an individual supporter);
  • To analyse and improve the content and operation of our website;
  • To analyse and improve our internal business processes;
  • To analyse the personal information we collect about you and use publicly available information to better understand your interests, preferences and level of potential donations so that we can contact you in the most appropriate way and to ensure that we do not send you unwanted communications;
  • To tailor advertising that is presented to you on the Internet according to your interests, preferences and other characteristics (as described below);
  • To direct advertisements and other communications to other people who may have similar interests or other characteristics to yours (as described below);
  • Where we are required by law to disclose or otherwise use your information.

In particular, we may contact you for marketing purposes by email or text message if you have agreed to be contacted in this manner.  We may also send you service communications via email or text, for example where you place an order for goods or services on our website, or you have made a donation by text.

If you have provided us with your postal address or telephone number, we may send you information about our work or other communications of the kinds described above by direct mail or contact you by telephone unless you have told us that you would prefer not to hear from us in this way.  We provide information about how you can change your marketing preferences below.

HOW WILL WE COMBINE AND ANALYSE THE INFORMATION WE COLLECT ABOUT YOU?

We carefully manage the communications we send you to ensure that we are contacting you in the most appropriate way and that we are not sending you unwanted communications.  In order to do this, we may combine the information that we collect about you and analyse what we know about your interests, preferences and level of potential engagement or donation. We may also use statistical analysis to analyse this data and understand the likelihood that you will be interested in or responsive to a campaign or message.

We may use third party service providers to assist us in this process.  For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.

Where we have identified that you have the capacity or affinity to support KHULA EDUCATION (KHULA)  at a higher level, we may collect additional information about you (see ‘What information do we collect?’) and combine and analyse that information in a profile of you that will assist us in engaging with you in a more personalised way.

You can opt out of your data being combined and analysed for marketing purposes by emailing: sarah@khula.org.uk . However, this may mean that you stop receiving marketing communications from us more generally, as we will be unable to determine their relevance to you.

In accordance with our legal and regulatory obligations and our internal policies and procedures, we may also use personal information to carry out due diligence on potential or actual donors.  If you opt out of analysis of your data for due diligence purposes, we may not be able to accept donations from you.

HOW WILL WE DISCLOSE THE INFORMATION WE HAVE COLLECTED TO OUTSIDE PARTIES?

KHULA EDUCATION (KHULA) may provide your information to our service providers. Subject to your communication preferences and our internal policies and procedures, this would include providing your information to third parties that work with us to deliver on our charitable purposes, and other entities that act as fundraisers for KHULA EDUCATION (KHULA or provide KHULA EDUCATION (KHULA) with marketing information and services.

Where you have agreed to receive email or SMS marketing communications from us, we may provide your email address or mobile phone number in an encrypted format to social media companies, such as Facebook, Instagram, Twitter or YouTube, or to digital advertising networks that are providing services to us by displaying our advertising to you on those social media platforms and other websites, as well as identifying audiences with interests similar to yours. You can opt out of your data being used to display advertising to you by contacting sarah@khula.org.uk. However, this will not prevent our advertisements being shown to you on a randomised basis or based on cookie data and may mean that you stop receiving marketing communications from us more generally.

We enter into contracts with our service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.

We will never sell your details.   We will only share your details with third parties (who are not service providers working at our direction) as indicated in this Policy or if you have consented or we have another legal basis to do so.  We will not make cold telephone calls to members of the general public for individual support and, therefore, will not purchase your data in order to do so.

We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect KHULA EDUCATION (KHULA), for example in cases of suspected fraud or defamation, or in order to comply with any other applicable legal obligation.

Your Rights

Individuals in the EEA (“European Economic Area”) have certain data subject rights which may be subject to limitations and/or restrictions. These rights include the: (i) right to request access to and rectification or erasure of their personal information; (ii) right to obtain restriction of processing or to object to processing of their personal information; and (iii) the right to data portability. Individuals in the EU also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.

If you have any questions as to this Privacy Policy or wish to notify us of any errors or changes as to any personal information you provide us through this website or if you are based in the EEA and would like to exercise your data subject rights, you can email us at sarah@khula.org.uk or write to us at 26 Gosfield Street, London W1W 6HH

International Use

 You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and website access.

Security/Cookies/Links

  • Security measures we put in place to protect your personal information:Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
  • Use of ‘cookies‘:Like many other websites, our websites use cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website). ‘Cookies’ are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit. It is possible to switch off cookies by setting your browser preferences. For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy Page
  • Links to other websites: Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third-party website we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website. 

Marketing 

  • If you make an enquiry about our Fundraising Opportunities or Partnering with us or enter into a contract with us for any service or programme, we may from time to time send you updates on fundraising events and initiatives or let you know about any other opportunities to help KHULA EDUCATION (KHULA).
  • From time to time we may also contact you about events that are being held
  • Where you are an individual (rather than an officer or employee of a company or corporate body), and where you have not entered into a contract with us for our services, we will only send you unsolicited marketing material by email if you have consented for us to do so on the website contact form.
  • You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please email Sarah Wilson at sarah@kula.org.uk requesting the withdrawing of your consent or objecting to our use of your personal information. 

Privacy Policy Changes

We may revise or supplement this policy from time to time. If we make any substantial changes in the way we use or share your personal information, we will notify you by posting a prominent announcement on our website prior to the change becoming effective. You may determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date of Current Policy” date noted at the bottom of this page. We encourage you to refer to this policy on an ongoing basis so that you understand our current Privacy Policy.

Effective Date of Current Policy: 1st February 2019.