Last updated: September 24th 2020
The Mike Procter Foundation UK – Registered Charity Number 1179346 (“us”, “we”, or “our”) operates the Mike Procter Foundation UK website, administers the Foundation and supports the work of those furthering our charitable objectives (the “Service”). We are the controller and responsible for your Personal Information that we collect and process.
This page informs you of our policies regarding the collection, use and disclosure of your Personal Information (as defined below) when you use our Service.
Information We Collect About You
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information (“Personal Information”) may include, but is not limited to:
Name and Contact Details:
• First Name
• Last name
• Username or similar identifier
• Date of birth
• Email address
• Telephone number
• Billing address
Financial and Transaction Data:
• bank account
• payment card details
• details about payments to and from you
Marketing and Communications Data:
• your preferences in receiving marketing from us and our third parties and your communication preferences
Special Category Data:
We do not currently collect or process special category data about you and we would only collect this with your explicit consent. If you provide this information to us in communications with our team, then we will treat this as you providing your explicit consent for us to collect and process this information.
Technical data is information that your browser sends whenever you visit our Service (“Log Data”). Log Data may include information such as:
• your computer’s Internet Protocol (“IP”) address;
• your browser type;
• your browser version;
• the pages of our Service that you visit;
• the time and date of your visit;
• the time spent on those pages; and
• other statistics.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Where we need to collect personal data by law, or under the terms of an agreement 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.
How is Your Data Collected?
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact 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:
• fill out a contact form;
• create an account on our Service;
• when making a purchase or a donation through our website;
• request our newsletter to be sent to you; and/or
• give us some feedback.
Automated technologies or interactions:
As you interact with our Service, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
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:
o analytics providers;
o advertising networks;
o search information providers;
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services; and
o Any other ways you collect personal data.
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 have your consent to using your personal data for a particular purpose;
• where we need to perform our obligations under any agreement we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and/or
• where we need to comply with a legal or regulatory obligation.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
• Promotional offers from us
o 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);
o You will receive marketing communications from us if you have requested information from us and in each case, where you have not opted out of receiving that marketing.
• Third-party marketing
o We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
• Opting out
o You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
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.
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used. We may need to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Service providers [acting as processors] who provide IT and system administration services:
• Professional advisers including lawyers, bankers, auditors and insurers;
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and
• 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 Charities or merge with them. If a change happens to our business, then the new owners 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.
International Transfers of Your Personal Data
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:
• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (South Africa falls within this category);
• where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• 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.
The security of your Personal Information is important to us. 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.
Please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Links To Other Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
How Long Will We Use Your Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
We do not knowingly collect Personally Information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we discover that a child under 18 has provided us with Personal Information, we will delete such information from our servers immediately.
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 any applicable 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 if and 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 our obligations under an agreement 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.
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.
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.
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.