Introduction
Welcome to The Guardiola Sala Foundation’s (“We”, “Us”, “Our”) website privacy policy.
We respect your privacy and are committed to protecting your personal data. This privacy policy 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 policy.
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website and any associated products, including any data you may provide through this website when you donate to us. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
The Guardiola Sala Foundation is the controller responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at info@guardiolasala.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 policy and your duty to inform us of changes
We keep our privacy policy under regular review. We will publicise any substantial changes to this privacy policy on our website.
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. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data 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 such as title and name.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account and payment card details, for example when you donate through our website.
Transaction Data includes details about payment method information (such as card number, bank account information or payment card image), billing address, date of donation, donation amount.
Technical Data includes internet protocol (IP) address, 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 interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, for example how long you spend on a given page.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 page or 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 policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or donating on our website. This includes personal data you provide when you donate on our website or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Contact, Financial and Transaction Data from providers of payment processing services on our website.
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 perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you electronically. You have the right to withdraw consent to marketing at any time.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all 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 interests 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 |
Lawful basis for processing including basis of legitimate interest |
|
To manage donations |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Our legitimate interests to keep you updated on other opportunities to support out work |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Technical |
(a) Necessary for our legitimate interests (for provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation |
|
To use data analytics to improve our website, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about events or other opportunities that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to deliver our charitable activities) |
Direct Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around direct marketing.
Opportunities to support us or attend our events
You will only receive marketing communications from us if you have requested information from us or donated to us and you have opted in to receive that marketing.
Third-party marketing
We will get your express consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing communications at any time by following the opt-out links on any communication sent to you.
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 our website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.
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.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
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.
We share your personal data with certain service providers, for example payment processing providers on our website that we use to process donations. This may involve transferring your data outside the UK. Whenever we transfer your personal data out of the UK, we ensure the recipient organisation offers a similar degree of protection to it as we would in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. Sometimes, we may be required to retain your personal data for longer for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may also retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In certain circumstances, 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 interest (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:
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.
If you wish to exercise any of the rights set out above, please contact us at info@guardiolasala.org.
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 or refuse to comply if your request is clearly unfounded, repetitive or excessive.
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 exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you for further information in relation to your request if we need any clarification.
Time limit to respond
We will respond to all legitimate requests within one month. Occasionally it could 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.
LAWFUL BASIS
THIRD PARTIES