Effective 25th May 2018 – version 1.0
1.1. We are committed to safeguarding the privacy of our website visitors and supporters of the Goodwin Sands SOS campaign.
1.2. We have prepared this privacy statement in accordance with the new EU GDPR guidelines enforced from May 25th 2018 onwards.
1.3. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and supporters; in other words, where we determine the purposes and means of the processing of that personal data.
1.5. Our website is hosted in the UK.
1.6. Our website uses Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website.
1.7. In this policy, “we”, “us” and “our” refer to Goodwin Sands SOS. “The campaign” refers to the campaign to protect the Goodwin Sands from dredging by Dover Harbour Board.
2. Our details
2.1 This website is owned and operated by Goodwin Sands SOS.
2.2 You can contact us:
(a) By using our website contact form.
(b) By email, using firstname.lastname@example.org.
(c) Via our Facebook group at: https://www.facebook.com/groups/SaveOurSands/
(d) Via our Twitter account @GoodwinSandsSOS at: https://twitter.com/GoodwinSandsSOS
(e) By post at: Goodwin Sands SOS, 32 The Beach, Walmer, Kent CT14 7HN.
3. How we use your personal data
3.1 In this section we have set out:
(a) the general categories of personal data that we may process.
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data.
(c) the purposes for which we may process personal data.
(d) the legal bases of the processing.
3.2 Usage data: We may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is legitimate interests, namely monitoring and improving our website and services.
3.3 Account data: We may process your account data which may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, management of and development of the campaign, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and campaign.
3.4 Publication Data: We may process information that you post for publication on our website or other locations such as social media. The publication data may be processed for the purposes of enabling such publication and administering our website and campaign. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and campaign.
3.5 Enquiry data: We may process information contained in any enquiry you submit to us regarding the campaign. The enquiry data may be processed for the purposes of the campaign. The legal basis for this processing is consent.
3.6 Transaction data: We may process information relating to transactions, including donations to the campaign through our website. The transaction data may include your contact details and the transaction details not including your card details. The transaction data may be processed for the purpose of keeping proper records of those transactions. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and campaign.
3.7 Notification data: We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.8 Correspondence data: We may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and campaign and communications with users.
3.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our campaign against risks.
3.11 We carry out a variety of activities to seek individuals’ support for our work, ranging from appeals for small one-off donations, to large fundraising initiatives for specific projects or requirements. We want to ensure that we are contacting you with tailored and appropriate communications, and ensure we direct our resources and fundraising activities as efficiently and effectively as we can. We also want to communicate with you from time to time to thank you for your support and tell you what we have achieved with the help of your donation.
3.12 In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 Third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
We use third parties to process personal data on our behalf. These third parties have been carefully chosen and are industry standards. All of them comply with the relevant legislation.
4.3 In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Transfer of your personal data within the EEA
5.1 In this section, we provide information about the circumstances in which your personal data may be transferred to countries within the European Economic Area (EEA).
5.2 PayPal (Europe)
Financial transactions including donations relating to our website and campaign are handled by our payment services providers, PayPal (Europe). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your donations, payments, refunding such payments and dealing with complaints and queries relating to such donations, payments and refunds. You can find information about their privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.
6. International transfers of your personal data
6.1 In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA) deemed to offer an adequate level of data protection.
6.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6.6 Any parties participating in the EU-U.S. Privacy Shield Framework Initiative can be checked here: https://www.privacyshield.gov/list
7. Retaining and deleting personal data
7.1 This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will hold your personal information on our systems for as long as is appropriate for the activity that you are supporting (for example participating in the campaign or making a donation to support our work).
7.4 Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Security of personal data
8.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
8.3 Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
8.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 We may change the policy because of changes in relevant and applicable legal or regulatory requirements, our practices, our attempts to better serve your needs or to add or modify services in use by the website.
9.3 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.4 We may notify you and others of changes to this policy by email or through social media.
10. Your rights
10.1 In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
10.2 Your principal rights under data protection law are:
(a) the right to access.
(b) the right to rectification.
(c) the right to erasure.
(d) the right to restrict processing.
(e) the right to object to processing.
(f) the right to data portability.
(g) the right to complain to a supervisory authority.
(g) the right to withdraw consent.
10.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
10.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
10.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. We may, however, retain a secure anonymised record for research and analytical purposes.
10.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
10.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
10.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
10.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
10.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section.
11. Third party websites
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties, however you are advised to read the Privacy Policies of third parties that we may use to embed in our site:
(a) YouTube (video sharing platform): https://support.google.com/youtube/answer/7671399
(b) Vimeo (video sharing platform): https://vimeo.com/privacy
(c) Twitter (social media platform): https://twitter.com/en/privacy
(d) Facebook (social media platform): https://www.facebook.com/full_data_use_policy
(e) Google (social media platform): https://policies.google.com/privacy
12. Personal data of minors
12.1 The protection of minors is very important to us, so we won’t actively seek opportunities to collect personal information from under-18s. However, we don’t want to exclude under-18s from opportunities to support our work either (with the exception of donations), so we may sometimes need to store their personal information. Where appropriate, we’ll ask under-18s for their date of birth to make sure they’re completely excluded from our fundraising activities.
12.2 Minors should always ask a parent or guardian for permission before sending personal information to anyone online.
13. Updating your information
13.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
14. Acting as a data processor
14.1 In respect of our use of 38 Degrees for our petition, we do not act as a data controller, instead, we act as a data processor.
14.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
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