Privacy Policy Privacy and cookies policy 1. Introduction 1.1 Just a Drop (the 'business'; 'we') are committed to safeguarding the privacy of Just a Drop website visitors and service users; in this policy we explain how we will handle your personal data. 1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. 1.3 This privacy policy was last updated on 4 June 2018 2. Credit 2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com). 3. How we use your personal data 3.1 In this Section 3 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; and (d) the legal bases of the processing. 3.2 Just a Drop's lawful basis for the processing of personal data includes: (a) Consent; namely all the data we hold is with your freely given, positive indication of consent. The purpose that we hold this data for is to: Keep you informed about Just a Drop’s work Send specific information about a project you may be interested in Ask for a donation to support our work (b) Contract; namely that the data we hold is necessary due to the fulfilment of a contract where that involves the payment of a salary, NI and pension, or a voluntary agreement. (c) Legal obligation; namely we hold data on a person as we have a contract with them, or we have been asked to do something before entering into a contract, for example, providing a project proposal. (d) Our legitimate interests; namely the proper administration of our website and business, monitoring and improving our website and services, and the protection and assertion of our legal rights, your legal rights and the legal rights of others. 3.4 The procedure for how we seek, record and manage consent is as follows. Consent must be: Freely given, specific, informed and unambiguous A positive opt-in Separate from other terms and conditions There is a simple way for you to withdraw, see section 7 3.5 We may process data about your use of our website and services ("usage data"). 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 our legitimate interests, namely monitoring and improving our website and services. 3.6 We may process your account data ("account data"). The account data 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, providing our services, 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 our legitimate interests, namely the proper administration of our website and business. 3.7 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. 3.8 We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering relevant services to you. The legal basis for this processing is consent. 3.9 We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website. ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business. 3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). 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. 3.11 We may process information contained in or relating to any communication that you send to us ("correspondence data"). 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 business and communications with users. 3.12 We may process any of your personal data identified in the other provisions of 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. 3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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 Financial transactions relating to our website and services are handled by our payment services providers, Stripe, GoCardless and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments. You can find information about the payment services providers' privacy policies and practices at: https://stripe.com/gb/privacy , https://gocardless.com/legal/privacy/ , https://www.paypal.com/ie/webapps/mpp/ua/privacy-full 4.2 Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply: Your data will be made available to our website provider The data that may be available to them include any of the data we collect as described in section 3 above. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA. They will store your data for a maximum of 7 years. This processing does not affect your rights under section 12 of this privacy policy 4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may also 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. 5. Retaining and deleting personal data 5.1 This Section 5 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. 5.2 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. 5.3 We will retain and delete your personal data as follows: (a) Personal data will be retained for 7 years following the date consent is given, at the end of which period it will be deleted from our systems. 5.4 Notwithstanding the other provisions of this Section 5, 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. 6. Amendments 6.1 We may update this policy from time to time by publishing a new version on our website. 6.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 6.3 We may notify you of changes to this policy by email. 7. Your rights 7.1 For all individuals, Just a Drop respects the following rights: (a) The right to be informed about the data we hold on you; (b) The right of access to that data; (c) The right to rectify the data we hold; (d) The right for that data to be erased; (e) The right you have to restrict processing of that data; (f) The right of data portability, even if this may not be relevant; (g) The right to object to the data we hold; (h) The right not to be subject to automated decision-making including profiling. 7.2 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: (a) the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address. 7.3 When we receive a request to provide you with any personal information we hold about you, we will follow the following procedure: (a) We will deal with all such requests in a professional and polite manner; (b) We will manage such request subject to the requirements of GDPR; (c) We will make no charge to handle such a request; (d) We will comply with the request within 1 month; (e) We reserve the right to refuse a request which we believe to be unfounded or excessive; (f) If we refuse to provide access, we will say why and that you have the right to complain; (g) We will communicate the lawful basis for which your data has been held. 7.4 We may withhold personal information that you request to the extent permitted by law. 7.5 You may instruct us at any time not to process your personal information for marketing purposes. 7.6 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. 8. Third party websites 8.1 Our website includes hyperlinks to, and details of, third party websites. 8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties. 9. Personal data of children 9.1 Our website and services are targeted at persons over the age of 18. 9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data. 10. Updating information 10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated. 11. About cookies 11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 12. Cookies that we use 12.1 We use cookies for the following purposes: (a) authentication - we use cookies to identify you when you visit our website and as you navigate our website. (b) status - we use cookies to help us to determine if you are logged into our website. (c) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally. (d) analysis - we use cookies to help us to analyse the use and performance of our website and services. 13. Cookies used by our service providers 13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 13.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/ 14. Managing cookies 14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 14.2 Blocking all cookies will have a negative impact upon the usability of many websites. 14.3 If you block cookies, you will not be able to use all the features on our website. 15. Our details 15.1 This website is owned and operated by The Just a Drop Appeal. 15.2 We are registered in England and Wales under registration number 4340715 and our registered office is at 28 The Quadrant, Richmond, Surrey, TW9 1DN. 15.3 Our principal place of business is at 28 The Quadrant, Richmond, Surrey, TW9 1DN. 15.4 You can contact us: (a) by post, using the postal address 28 The Quadrant, Richmond, Surrey, TW9 1DN; (b) using our website contact form; (c) by telephone, on +44 (0)20 8910 7981 (d) by email, using [email protected] 16. Data breaches 16.1 Section 16 outlines the procedure Just a Drop will follow in detecting, reporting and investigating any data breach. 16.2 Just a Drop’s Richmond office is within Reed Exhibitions, so we will follow the policies they operate to detect a data breach. 16.3 We have identified that we store data in a number of sources and we will ensure that these places are: (a) Password protected and that passwords are regularly changed; (b) Supported by relevant software; (c) Kept in a secure location which can only be accessed by staff who are authorised to. 16.4 We will report a breach to the ICO, as such a breach could compromise bank account details resulting in a financial loss this is only where such a breach can result in a risk to the rights of freedoms of individual. 16.5 We will contact those individuals whose data has been breached to notify them and advise them of any action they may need to take. 16.6 We will investigate how the breach has happened and ensure relevant steps are taken to ensure it does not happen again. 17. Complaints 17.1 If you have a complaint about us, or the treatment of your data, you can contact the Charity Commission. The Charity Commission is the independent watchdog for charities. You can make a complaint about a charity on their website at www.charity-commission.gov.uk.