1. Purpose of this Notice
Campaign Innovation Limited (“we” or “us”) takes the protection of your personal data seriously. This Privacy Notice explains how we use any personal information that you supply to us, or that might be collected from a third party, and sets out your rights in respect of our processing of your personal information. We process data in accordance with UK Data Protection Laws which includes but is not limited to the UK General Data Protection Regulation (UK GDPR) , The Privacy and Electronics Communications Regulation (PECR) and the Data Protection Act 2018. If you reside outside of the UK, other laws may be applicable.
In particular, this Notice explains:
the kinds of personal information we collect about you;
the means by which we obtain your personal information;
the ways in which we use your personal information;
the basis on which we use your personal information;
the length of time that we keep your personal information;
who we share your personal information with;
how we protect your personal information; and
where and why we transfer your personal information outside of the UK.
We may collect your personal data in your capacity as a volunteer, donor, applicant, purchaser from our online shop, participant in our events, applicant to our programmes, subscriber to our marketing lists, or because you are a subscriber or visitor to our website (the “Site”).
This Privacy Notice is intended to assist you in making informed decisions about your personal data. Please take a moment to read and understand it.
2. About Us
Campaign Innovation Limited is a registered company (company number 12374351). Our principal and registered address is 86-90 Paul Street, London, EC2A 4NE. As such we are a Data Controller in accordance with the Data Protection Act 2018 and are registered with the Information Commissioner’s Office with reference number: ZB264085 .
3. How to Contact Us
If you have any questions about this Notice or want to exercise your privacy rights, please contact us by: writing to us at Privacy Enquiries, Campaign Innovation Limited, 86-90 Paul Street, London, EC2A 4NE
4. How We Collect Your Personal Information
We may collect your personal information in the following ways:
When you give it to us directly. You may give us your personal data directly in various ways, for example when you apply to attend one of our events, when you interact with us on social media, when you apply for employment with us, when you apply to volunteer with us, when you apply to receive funding from us, when you contact us by phone, social media, email or post or when you donate money to us.
When we receive your information indirectly your information may be shared with us by third parties, for example independent event organisers, other fundraising entities, other grant making entities, sponsors and supporters of our organisation and services. Your information may also be provided to us when you follow us or otherwise interact with us on or via Twitter, when you like and/or join our page on Facebook, Instagram, Youtube or Whatsapp or interact with us in other ways on or via Facebook, Instagram, YouTube or Whatsapp.
When you give permission to other organisations to share it with us or in some cases if you have made it publicly available. We may combine information you provide to us with information available from external publicly available sources. We use this information to gain a better understanding of you and to improve our communications and fundraising activities but only where this is not considered to be intrusive.
When you visit our website, we use cookies when you visit our website, which may record personal information about you. Please refer to our Cookies Notice, below, for details on the way we use cookies. We will ask you for your consent to use cookies, you are not obliged to give us your consent. Your consent is not a precondition for using our website.
5. The Information We Process
We may process the following kinds of personal data:
your name and contact details, including physical address, telephone number and e-mail address, and social media identity;
financial information, such as payment-related information, including bank details or debit/credit card details;
personal information we receive in the course of providing services to you, including details of why you have decided to contact us/apply to one of our events, details of trainings you have attended, details of topics/areas of interest to you, responses to surveys you have completed;
technical information, including information about your visits to and use of our Site and the device you used to access the Site, your IP address, geographical location, browser type, referral source, length of visit and number of page views;
marketing information, including information about the services you use, services and products of interest to you or any marketing and/or communication preferences you give; and/or any other information shared with us as per paragraph 1 above.
We may process the following kinds of special category data:
your ethnic origin;
details of any dietary requirements;
details of any disability or access requirements;
although we do not routinely process data relating to health in addition to the disability and access requirements data mentioned above, we may process data relating to health, including mental health, if you disclose this information to us and either you have given us your explicit consent to process it or we consider that it is necessary to process it in order to protect your vital interests; we have a separate Safeguarding Policy for the protection of vulnerable persons.
6. How and Why We Use Your Personal Data
We may use your personal information to:
Advance our objects: to advance any purpose for the benefit of society, nationally or internationally, and such other purposes as the directors of the Company may determine from time to time.
Manage and administer our relationship with you, including providing you with services and information you have requested
Market our services, including sending you information about our work, funding opportunities, trainings, organisation and any other information, products or services that we provide;
Administer our Site, including monitoring its use;
Administer payments;
Administer your employment and/or volunteering application;
Conduct research and data analysis into the impact of our programmes;
Deal with enquiries and complaints made by or about you relating to the Site or us in general;
Audit and/or administer our accounts;
Conduct supporter research and profiling;
Manage individuals’ preferences, including administering suppression files;
Administer security requirements, including data and systems security;
Conduct financial management and control;
Meet any of our legal, regulatory and risk management obligations.
We may share information with third parties who may potentially fund projects. This may include but is not limited to a funding application.
We may share other personal data where it is in our interest to do so but only where the law permits.
Using our services
If you apply to receive funding from us, or access any programmes we may offer then we will process your personal information in order to consider your application and, if successful, provide that service to you
Supporter/research profiling
We may use your personal information to undertake research to gather further information about you from publicly accessible sources. This helps us gain a better understanding of your background, interests and preferences, in order to improve our communications and/or interactions with you, to help ensure they are targeted to be relevant and appropriate, and to provide information about programmes and other aspects of our services which we consider may be of interest to you.
Marketing
Marketing methods
Where you have provided us with your physical address, we will contact you by post and where you have provided appropriate consent, also by email, with targeted marketing communications to let you know about our events and/or activities that we consider may be of particular interest, about the work of the company and to ask for donations or other support.
Facebook marketing
We may use some of your personal information to participate in Facebook’s Custom Audience and Lookalike Audience programs, which enable us to display adverts to both existing and prospective supporters when they visit Facebook. We may provide your email address to Facebook so that Facebook can determine whether you are a registered account holder. Our adverts may then appear when you access Facebook. For more detailed information please see https://www.facebook.com/business/help/744354708981227 and Facebook’s data policy at https://en-gb.facebook.com/policy.php.
Using our Site
When you use our Site, you may be asked to provide us with personal information. When you provide us with personal information in this way, we only use it for the purposes stated to you at the time we collect the information.
We also use cookies on our Site, which may collect your personal information. For example, we may use Google Analytics to review some of your personal information, in order to analyse our digital performance, record how you are using our Site and/or assess the popularity of marketing campaigns. This helps us improve our Site.
Payments
Financial transactions carried out on our website are handled through Stripe, Inc. (“Stripe”) GoCardless and PayPal, third party payment services providers. We recommend that you read Stripe’s privacy policy, GoCardless’ privacy policy and PayPal’s privacy policy (available at https://stripe.com/gb/privacy and https://gocardless.com/legal/privacy and https://www.paypal.com/uk/webapps/mpp/ua/privacy-full) prior to effecting any transactions with us. We will provide your personal data to Stripe, PayPal, or GoCardless only to the extent necessary for the purposes of processing payments for transactions you enter into with us. We do not store your financial details.
We do, from time to time, use other third-party donation platforms or payment processors and recommend that you read their privacy policy before using them. The platforms we currently use are GoFundMe, Facebook Donations and PayPal.
7. Lawful Basis for Processing your Personal Information
We are required to have one or more lawful grounds to process your personal information. We use your personal information on the following bases:
Personal information may be processed on the basis of a data subject’s consent
Personal information may be processed on the basis of a contractual relationship
Personal information may be processed on the basis of legal obligations
Personal information may be processed on the basis of legitimate interests
Consent
We will ask for your consent to use your information to send you electronic communications such as newsletters and marketing and fundraising emails, for targeted advertising, and if you ever share special category data with us. We will endeavour to ensure you are informed about what you are consenting to. You may withdraw your consent at any time.
Contractual relationships
Most of our interactions with subscribers and website users are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people. For example, if you apply for employment with us.
Legal obligations
Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when strictly necessary.
Legitimate interests
Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights). Wherever we use this lawful basis you have the right to Object to such processing.
We will rely on this ground for processing the data of all applicants and attendees of our programs, managing our fundraising activities and promoting our programs to relevant organisations, where their information is publicly accessible.
Where we have relied upon your consent as the ground for lawful processing, you are entitled to withdraw your consent at any time, and such withdrawal of consent will not undermine the lawfulness of processing based upon consent prior to the withdrawal.
We may use a combination of these lawful grounds for processing your data but not for the same purposes.
In you wish to exercise either of these rights, then please contact us as directed in Section 15 of this Notice.
8. Children’s Data
Our services are not aimed at children and we do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that you are 15 and under and we are holding your personal information, we will delete that information within a reasonable period and withhold our services accordingly.
9. Security of and Access to Your Personal Data
We have in place appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure of or access to your personal information.
Your information is only accessible by appropriately trained staff, volunteers and contractors and we provide training on the protection of personal data.
We may transfer and/or store personal data collected from you to and/or at a destination outside the European Economic Area (“EEA”). Such personal data may be processed by agencies and/or suppliers operating outside the EEA, where the standard of protection for personal data may be lower than in the EEA, including lower security requirements and fewer rights for individuals. If we transfer and/or store your personal data outside the EEA we will take reasonable steps to ensure that the recipient of your data implements appropriate measures to protect your personal data. Such measures may include but are not limited to EU Standard Contractual Clauses or UK equivalent safeguards. Such safeguards will be implemented on a case by case basis.
10. Your Rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time. You also have the following broad rights but please note that they may only apply in certain circumstances:
Right to be informed – you have the right to be told how your personal information will be used. This notice and other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we have one month (although those time limit may be extended in certain circumstances).
Right of erasure – You may ask us for your personal information to be deleted from our records in certain circumstances.
Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
Right to restrict processing – you have the right to ask for processing of your personal data to be restricted in limited circumstances, including if you dispute its accuracy or while an objection to processing on the ground of legitimate interests is under investigation.
Right to data portability – in certain circumstances, you have the right to ask us to provide data you have sent to us to another service provider in a machine-readable format.
Right to object to processing – you have an absolute right to object to processing for direct marketing purposes and a qualified right to object to processing in certain other circumstances, for example on the ground of legitimate interests. In order to unsubscribe from any receiving any communications from us, please contact us using the details below.
To exercise any of the above rights, please contact us using the details in section 15 below. For further information on your rights as a data subject, we suggest that you consult the guidance of the Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
Finally, you are further entitled to make a complaint to the ICO about us or the way we have processed your personal data. For further information on how to exercise this right, please see the guidance at https://ico.org.uk/for-the-public/personal-information. The contact details of the ICO can be found here: https://ico.org.uk/global/contact-us/.
12. Data Retention
We keep your personal information only for as long as is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
13. Notice Amendments
We keep this Privacy Notice under regular review and reserve the right to amend it from time to time by posting an updated version on our Site, not least because of changes in applicable law. We recommend that you check this Notice occasionally to ensure you remain happy with it. We may also notify you of changes to our Notice by email.
14. Third Party Websites
We link our Site directly to other websites. This Privacy Notice does not cover third party websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.
15. Contacting Us
You may contact us with any privacy concerns – including to update your information or exercise your rights as a data subject – by contacting us using the details in section 3 above.
