Privacy Policy | Action Against Hunger WHY HUNGER? OUR IMPACT GET INVOLVED Sitewide Search Sitewide search, click to expand DONATE NOW Responsive nav PRIVACY POLICY This privacy policy sets out how we collect, use and store your personal information. It also states how and why we use data, how we store it and how we can amend your personal preferences if you would like to change how we contact you. We take the privacy of the people we help across the world, and of our supporters and volunteers very seriously. We’re committed to protecting your privacy and we’ll make sure that your information is kept secure. Please read this policy carefully. The terms of this policy may change, so please check it from time to time. This version published in November 2020 supersedes all previous versions. If you have any questions, please call our Supporter Care team on 020 853 7571 or email support@actionagainsthunger.org.uk. Who we are Action Against Hunger UK Limited (‘Action Against Hunger’) is a registered charity and our registration number is 1047501 in England and Wales and SC048317 in Scotland. We’re also a company limited by guarantee incorporated in England (company number 03069468) and have a wholly owned trading subsidiary called Action Against Hunger Enterprises Limited (company number 06569439). Our registered address is 6 Mitre Passage, London SE10 0ER. We’re a “data controller” for the purposes of the EU General Data Protection Regulation (GDPR). This means that we’re responsible for, and control the processing of, your personal information. Why we hold and process supporters’ personal data GDPR provides the legal framework that defines how we can use personal information. We’re fully committed to complying with the principles set out in GDPR and have a legal duty to protect any information we collect from you. In summary: Your personal information is only used for the purpose for which we collect it We will hold your personal information on our systems only for as long as is necessary for the relevant activity, for example we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules Your personal information is only seen by those who need it to do their jobs We’ll only disclose data when we have your consent, where we are obliged to disclose personal data by law, or as expressly permitted under the GDPR (through contracts, legal obligation, vital interests; public tasks, or legitimate interests) We’ll keep your information up to date. Inaccurate or misleading data will be corrected as soon as possible Your information will be protected from unauthorised or accidental disclosure and processed in an appropriate manner to maintain its integrity and confidentiality We’ll provide you with a copy of your personal information on request These principles apply whether we hold your information on paper or in electronic form. How we collect information When using the term “personal data” in this privacy policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Information is critical for us to carry out our vital work. It helps us to operate as efficiently as possible and to make sure our interactions with you are timely, relevant and tailored. To do this, we may collect information about you in the following ways: When you interact with us directly, for example by making a donation, enquiring about our work or signing up to newsletters. Sometimes, you may be interacting with an organisation working on our behalf, but we are still responsible for your information. When you interact with third parties, for example when making donations to fundraising pages through a third-party website such as Just Giving, or signing up to an event on EventBrite, and give permission for your information to be shared with us. Similarly, if you engage with us on social media and messaging services like Facebook or WhatsApp, or email services we use such as Mailchimp, you might give us permission to access information from those accounts. The data we have access to may vary by each third party but will also be in line with the terms and conditions of that particular service. When you visit our website we may gather information such as what pages you visit or how long you spend reading that particular page. This data helps us to improve your online experience, by informing our choice of words and images that appear on the site We occasionally use session recording or click tracking software, such as Hotjar to understand how you interact with our website. For example, scrolling down the webpage, or clicking your mouse on a particular link. This helps us to improve design and functionality. None of the information you provide when completing a form or typing during these sessions is recorded. We do not receive information about other sites you may view. Like most websites, we use cookies to help us do this, but wherever possible we use aggregated, anonymous data that does not identify individuals. Find out more about how we use your cookies. We may also receive information about you from third parties, for example from mailing list brokers and media companies. We will only ever collect the information that we need, including data that will be useful to help improve our services. We either need the information to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our sites. What information we collect We only collect personal data relevant to the type of interactions you have with Action Against Hunger. The personal information we collect might include name, date of birth, email address, postal address, telephone number, and taxpayer status (for Gift Aid eligibility). We may also collect information about the donations you make to us, events you register to attend, any fundraising you do for us, and details from any interactions you have with our Supporter Care team. Sensitive personal data We do not collect “sensitive personal data” about our supporters, e.g. health status, unless there is a clear reason for doing so, for example participation in a marathon or similar fundraising event where we need this to ensure that we provide appropriate facilities or support to enable you to take part. All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it. Why we collect information We collect and hold supporters’ personal information so that we can promote our work. We will ask for your consent before we use your information for certain purposes, such as sending you emails about upcoming events. We may also use your information where we have a legitimate interest in order to carry out our activities. Examples of this include: providing you with services, products or information you have requested, or that we feel would be of interest to you and reasonably expected by you processing donations, payments, gift aid, event registrations or other administrative activities providing you with personalised updates on our work and the difference your support is making, and providing you with other ways you can support us, where you have agreed to receive this conducting market research or asking you to participate in surveys analysing and improving our website, services, products and communications understanding our supporters better and keep a record of your relationship with us Who we share your information with We’ll only use your information for the purposes for which it was obtained. We won’t, under any circumstances, share or sell your personal data with any third party for their own marketing purposes. You will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us. We may need to share your personal information with partners, suppliers or agents to allow them to perform services on our behalf or help us to understand more about our supporters. In such cases, information is only shared for the purpose of providing services on our behalf relating to communications, or agreements between yourself and Action Against Hunger. We carry out this processing under the relevant data processing agreements. We also may need to disclose your information if required to do so by law or as expressly permitted under applicable data protection legislation. Our website may include links to websites run by other organisations. Action Against Hunger is not responsible for the privacy practices of these other websites so you should read their privacy policies carefully before sharing any personal or financial data. We have contracts in place with third party suppliers, partners and agents that we work with, and we require them to comply with the GDPR. We may provide your email address or mobile phone number to digital advertising or social media companies who work on our behalf, such as Facebook, Instagram, Twitter, YouTube, Google or LinkedIn. This is so we can reach you and others like you with our latest news and information on how to support us. This data is always provided in an encrypted format and is deleted immediately after use. If you don’t want to see targeted advertising from us on social media, please refer to the instructions provided by the relevant website or app. Some of the examples of organisations with which we may share your data include: social media partners fundraising partners mailing houses or fulfilment partners media partners companies that help us to process donations and transactions analysis and research partners database partners Storing and protecting your information We recognise the concerns that many people have about giving personal information online. We place great importance on the security of all personally identifiable information associated with our beneficiaries and supporters, as well as prospective, current and previous staff, consultants and volunteers. We have security measures in place to protect against the loss, misuse and alteration or destruction of personal data under our control. We store information electronically and we may also store information on paper files. We also use a secure server when you make a donation or payment via our website. However, no data transmission over the internet is 100% secure. As a result, while we cannot absolutely guarantee that loss, misuse or alteration of data will not occur while it is under our control, we use our best efforts to prevent this and protect your personal information. We use a set of controls to provide protection from the most prevalent cyber security threats. We will hold your personal information on our systems for as long as is necessary for the relevant activity. For example, we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules. If you request that we stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request. When your information is no longer required, we will always dispose of it securely, in accordance with our retention of records policy. Payment card information Action Against Hunger does not store any sensitive payment card data in our systems. We have an active PCI-DSS compliance programme in place. This is the international standard for safe card payment processes. Transfer of information outside of the EU Sometimes we may transfer information submitted by you to our other offices or we may need to use a service provider or partner outside the European Economic Area (EEA). This may include a country that does not have the same level of data protection as the UK. In these circumstances, we take all reasonable steps to ensure the safety and security of your information as set out in this privacy policy, including adhering to the EU-US privacy shield agreement. Your rights Action Against Hunger supports the principle of “fair and transparent” processing of your personal information. We support your rights in relation to your personal information under the General Data Protection Regulation. You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’). You can also request information on behalf of somebody else. We will ask you for proof of your identity and appropriate evidence of your right to access personal information on behalf of somebody else before we can act upon your request. You may ask us, or we may ask you, to rectify information you or we think is inaccurate. You can also ask us to remove inaccurate information or update information that is incomplete (‘right to rectification’). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records. If your personal details change, please help us to keep your information up to date by notifying us at the address below: You have a right to object to Action Against Hunger processing your personal information (‘right to object’) at any time where we rely on our legitimate interests for doing so. You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’). This right does not apply where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us. You have a right to seek the deletion of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example, where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest. You have a right to ask us to restrict our processing of your information (‘right to restriction’) if: you contest its accuracy and we need to verify whether it is accurate the processing is unlawful and you ask us to restrict use of it instead of erasing it we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests you exercise your right to restrict processing; we would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons If you would like to exercise any of your rights detailed above, please contact the Data Protection Officer at the address below. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge. Maria Franklin The Data Protection Officer Action Against Hunger UK 6 Mitre Passage London SE10 0ER Email: m.franklin@actionagainsthunger.org.uk (please state “Data Protection Right” in the subject line of your email) You also have a right to object to our processing your data for the purposes of marketing. Action Against Hunger always acts upon your choices around what type of communications you want to receive and how you want to receive them. You have a choice about whether you want to receive information about our work and fundraising activities. We make it easy for you to tell us how you want us to communicate with you. Our forms have clear marketing preference questions and if you do not want to hear from us then you can update your preferences. We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted. You can change your marketing preferences for what you receive from us and how, at any time, by contacting: Supporter Care Action Against Hunger UK 6 Mitre Passage London, SE10 0ER Tel: 0208 853 7571 Email: support@actionagainsthunger.org.uk If you have any concerns about our use of your data, you may also report these to the Information Commissioner’s Office. You can do so by calling their helpline on 0303 123 1113. Cookie policy The Action Against Hunger UK website uses cookies, tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device. COOKIE SETTINGS Trademarks and copyright Action Against Hunger’s websites contain material which is protected by copyright and/or other intellectual property rights. All copyright and intellectual property rights including the names, images and logos are owned by Action Against Hunger unless otherwise stated. All rights are reserved. You are responsible for complying with all applicable copyright laws. We permit you to make copies of information on the Action Against Hunger website as necessary incidental acts during your viewing and you may take a print for your personal use of so much of the site as is reasonable for private purposes. All other uses are prohibited. Nothing in these terms shall be construed as conferring any right to use any trademark, logo, patent right or copyright of Action Against Hunger UK. Changes to this privacy policy We may change the terms of this privacy policy on occasion, but we won’t reduce your rights under this privacy policy without your explicit consent. If we do we will post the changes here, so please check from time to time. We will also keep prior versions of this privacy policy in an archive. By continuing to use our websites, it is considered that you have accepted such changes. If you have any questions about this Policy, or how we use data please contact the Data Protection Officer at the above address. Further information and advice about data protection is available from: The Office of the Information Commissioner Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: +44 (0) 01625 545 745 Website: www.ico.org.uk Fundraising preference service We’re committed to empowering our supporters to manage their information. The Fundraising Preference Service (FPS) enables donors to take control of their charitable giving and conversations. We want to help you use the service effectively. We support the Fundraising Regulator and its efforts to develop the Fundraising Preference Service as a means of rebuilding trust between charities and the public. We’re committed to upholding fundraising best practice and being as transparent as possible with our donors. 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