3. Collecting personal information The types of personal information we collect Expand 3.1 We may collect, store and use the following kinds of personal information: (a) information about your computer and about your visits to and use of our newsletter campaigns (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths); (b) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name, email address and email preferences), employer details (company), email preferences and how you heard about FTCT. (e) information that you provide to us when viewing our newsletters, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use); (f) information contained in or relating to any communication that you send to us or send through our newsletter (including the communication content and metadata associated with the communication and any information gathered on a form); (g) any other personal information that you choose to send to us. 3.2 Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.
4. Using personal information How we use your personal information Expand On the basis of our legitimate interest to run our charity and promote our services, we may use your personal information to: apply to a, b, c, d, e, f In order to complete the service you have requested we may use your personal information to: apply to h, i Where you have given consent we may use your personal information to: Applies to g, h, j, 4.1 Personal information submitted to us through our mailing list sign up form will be used for the purposes specified in this policy. 4.2 We may use your personal information to: (a) send you marketing communications (if you have requested it) relating to our charity which we think may be of interest to you, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications); (b) send you email notifications that you have specifically requested; (c) personalise newsletters for you; (d) enable your use of the services available on our website; (e) provide third parties with statistical information about our mailing list users (but those third parties will not be able to identify any individual user from that information); (f) verify compliance with the terms and conditions governing the use of our website and mailing list (including monitoring forms submitted sent through our website); and (g) enable us to complete automated decision making and profiling in order to enhance your experience of the mailing list; (h) to conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our charity; (i) Your data will also be available to our mailing list provider (Mail Chimp) and their sub-processors who, as detailed in Mail Chimp’s Data Processing Agreement perform critical services such as prevent abuse, support Mail Chimp customers and carry out analysis and research on demographics, interests and behaviour 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 your use of our mailing list (open activity and click activity) 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 follow will apply: Your data will be made available to our mailing list provider (Mail Chimp) The data that may be available to them include any of the data we collect as described in section 3 above. They will store your data until you request for it to be removed or deleted. This processing does not affect your rights under sections 10 or 16 of this privacy policy 4.3 Your privacy settings can be used to limit the frequency of emails and the subject matter and can be adjusted or removed by using the privacy settings link in the footer of each email or by contacting the charity. 4.4 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing. 4.6 We will share information with our mailing list provider only to the extent necessary for the purposes of administering our newsletter. Our mailing list provider (Mail Chimp) is based outside of the EEA (USA) and may transfer personal information to third party sub processors, in order to provide its services. All sub processors enter into a contract which restricts their use of personal information consistent with this policy. You can review Mail Chimp’s privacy policy at: https://mailchimp.com/legal/privacy/ A full list of Mail Chimp’s current sub processors is available upon request. Please email [email protected] to request this information.
5. Disclosing personal information Who has access to your personal information Expand 5.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers (including specifically the provider and host of our mailing list or other subcontractors insofar as reasonably necessary for the purposes set out in this policy. 5.2 Our mailing list provider (Mail Chimp) may disclose your personal information to any member of its group of companies (this includes sub processors, its ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy. 5.3 We may disclose your personal information: (a) to the extent that we are required to do so by law; (b) in connection with any ongoing or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); (d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information. 5.4 Except as provided in this policy, we will not provide your personal information to third parties.
6. International data transfers How data is shared outside of the EEA Expand 6.1 Our mailing list provider (Mail Chimp) operates outside the EEA (USA). Information that we collect may be stored and processed in and transferred between any of the countries in which we or our mailing list provider operates (USA) in order to enable us to use the information in accordance with this policy. Mail Chimp participates in and has certified its compliance with the EU-US Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework. More information about this can be found at: https://mailchimp.com/legal/privacy/ 6.2 You expressly agree to the transfers of personal information described in this Section 6.
7. Retaining personal information How long personal information is stored for Expand 7.1 This Section 7 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 information. 7.2 Personal information 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 Without prejudice to Section 7.2, we will usually delete personal data falling within the categories set out below at the date/time set out below: (a) personal data related to mailing list subscriptions will be deleted two years after you unsubscribe from our mailing list. 7.4 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data: (a) to the extent that we are required to do so by law; (b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8. Security of personal information Keeping your personal information safe Expand 8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. 8.2 We will store all the personal information you provide on our mailing list providers secure servers. This may include data storage services provided in the Cloud. 8.3 All electronic financial transactions entered into through our website will be protected by encryption technology. 8.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
9. Amendments How we update and amend this policy Expand 9.1 We may update this policy from time to time by publishing a new version in the footer of our newsletters. 9.2 You should check these links occasionally to ensure you are happy with any changes to this policy.
10. Your rights How to request access to your personal information Expand 10.1 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). 10.2 We may withhold personal information that you request to the extent permitted by law. 10.3 You may instruct us at any time not to cease processing your personal information for marketing purposes. You can do this using the unsubscribe link in the footer of our emails or by emailing [email protected]. 10.4 In practice, you will usually expressly agree in advance to our use of your personal information for marketing purpose. We will always provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
11. Third party websites Privacy policy use for third party websites Expand 11.1 Our mailing list includes hyperlinks to, and details of, our website and third party websites. 11.2 This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them. If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data 11.3 We operate a number of social media pages (including Facebook, Twitter, You Tube and Instagram). Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.
12. Updating your information Expand 12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated. You can do this by emailing [email protected] or using the 'update preferences' tab in the footer of all our email newsletters.
13. Cookies How our mailing list provider uses cookies Expand 13.1 Our mailing list provider (Mail Chimp) uses cookies. 13.2 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. 13.3 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. 13.4 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. 13.5 Our mailing list provider (Mail Chimp) uses both session and persistent cookies and both ‘first party’ and ‘third party’ cookies. 13.6.1 Our mailing list provider (Mail Chimp) uses cookies for technical reasons in order to operate its website and services. 13.6.2 Our mailing list provider (Mail Chimp) also allows us to employ cookies and similar tracking technologies (web beacons) in connection with our use of their services, in order to allow us to track subscriber activities and generate statistical about subscriber mail use. 13.6.3 The information generated relating to our mailing list is used to create reports about how an email campaign performed and what actions subscribers took. 13.6.5 Our mailing list providers cookie policy is available at: https://mailchimp.com/legal/cookies/ 13.7 Most browsers allow you to refuse to accept cookies; for example: (a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced"; (b) in Firefox (version 47) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and (c) in Chrome (version 52), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading. 13.8 Blocking all cookies will have a negative impact upon the usability of many websites. 13.9 If you block cookies, you will not be able to use all the features on our website. 13.10 You can delete cookies already stored on your computer; for example: (a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11); (b) in Firefox (version 47), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and (c) in Chrome (version 52), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data". 13.11 Deleting cookies will have a negative impact on the usability of many websites.
14. Data protection registration Our data protection registration details Expand 14.1 We are registered as a data controller with the UK Information Commissioner's Office. 14.2 Our data protection registration number is Z4928022
15. Our details Our contact details Expand 15.1 This mailing list is controlled and operated by Fashion & Textile Children’s Trust. 15.2 We are registered in [England and Wales] under registration number 257136, and our registered office is at Victoria Charity Centre, 11 Belgrave Road, London. SW1V 1RB. 15.3 Our principal place of business is at Victoria Charity Centre, 11 Belgrave Road, London. SW1V 1RB. 15.4 You can contact us: (a) by post, using the postal address given above; (b) by telephone, on 0300 123 9002; or (c) by email, using [email protected]
16. Complaints How to make a complaint about personal information use Expand 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. If you've got a complaint about our fundraising activities you can also complain to the Fundraising Standards Board (FRSB). To find out whether a charity is an FRSB member and how to go about making a complaint, go to the FSRB public website at www.givewithconfidence.org.uk