PRIVACY POLICY

1.   INTRODUCTION

This privacy policy provides you with details of how we collect and process your personal data through your use of our website www.ortuk.org, including any information you may provide through our site when you book to attend an event, sign up to our newsletter or take part in a prize draw or competition.

By providing us with your data, you warrant to us that you are over 13 years of age.

ORT UK is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).

Contact Details

Our full details are:

Full name of legal entity: ORT UK   (Registered Charity No. 1105254)

Email address: info@ortuk.org

Postal address: ORT House, 126 Albert Street, London NW1 7NE

Telephone number: 020 7446 8520

 

If you are not happy with any aspect of how we collect and use your data please contact us as we would like to try and resolve the matter for you. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@ortuk.org

 

2.  WHAT DATA DO WE COLLECT ABOUT YOU

 

Personal data means any information capable of identifying an individual. It does not include anonymised data.

 

We may process certain types of personal data about you as follows:

 

•        Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.

•        Contact Data may include your home address, work address, email address and telephone numbers.

•        Financial Data may include your bank account and payment card details.

•        Transaction Data may include details about payments received from you to attend events and donations made by you.

•        Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.

•        Profile Data may include your interests, preferences, feedback and survey responses.

•        Usage Data may include information about how you use our website and services.

•        Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Special Category Data

 

We do not collect any Special Category Data about you. Special Category Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

 

3.  HOW WE COLLECT YOUR PERSONAL DATA

 

We collect data about you through a variety of different methods including:

 

•        Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

•        Make a donation;

•        subscribe to our news or events;

•        request resources or marketing be sent to you;

•        enter a competition, prize draw, promotion or survey; or

•        give us feedback.

•        Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies.

•        Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources including technical data from analytics providers such as Google based outside the EU.

 

4.  HOW WE USE YOUR PERSONAL DATA

 

We will only use your personal data when legally permitted. The most common uses of your personal data are:

 

•        Where we need to perform the contract between us.

•        Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

•        Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to opt out of receiving marketing at any time by emailing us at info@ortuk.org.

 

Purposes for processing your personal data

 

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

 

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at info@ortuk.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing

To register you as attending an event

(a) Identity

(b) Contact

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Marketing and Communications

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests to keep our records updated and to study how supporters use our services
To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications
(a) Performance of a contract with you

(b) Necessary for our legitimate interests to study how our services are used and grow the services we provide through fundraising

To administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, and to prevent fraud

(b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about events or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage
Necessary for our legitimate interests to develop our support and grow our charity

 

Marketing communications

 

You will receive marketing communications from us if you have:

 

(i)                 requested information from us, used our service, attended our events or made a donation; or

(ii)               if you provided us with your details and ticked the box at the point of providing your details for us to send you marketing communications; and

(iii)             in each case, you have not opted out of receiving that marketing.

 

We do not share your personal data with any third party for marketing purposes.

 

Change of purpose

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@ortuk.org.

 

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

 

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA

 

We may have to share your personal data with the parties set out below in order to provide services or support:

 

•        Service providers who provide IT and system administration services.

•        Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

•        HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

6.  INTERNATIONAL TRANSFERS

 

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

 

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

 

•        We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

•        Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

•        Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at info@ortuk.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7.  DATA SECURITY

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8.  DATA RETENTION

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

By law we may have to keep basic information about you (including Contact, Identity, Financial and Transaction Data) for seven years for tax and accounting purposes.

 

In some circumstances you can ask us to delete your personal information.

 

9.  YOUR LEGAL RIGHTS

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

 

•        Request access to your personal data.

•        Request correction of your personal data.

•        Request erasure of your personal data.

•        Object to processing of your personal data.

•        Request restriction of processing your personal data.

•        Request transfer of your personal data.

•        Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@ortuk.org.

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

10. THIRD-PARTY LINKS

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

11. COOKIES

 

Cookies and how they benefit you

 

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

 

Our cookies help us:

 

–           Make our website work as you’d expect.

–           Remember your settings during and between visits.

–           Improve the speed/security of the site.

–           Allow you to share pages with social networks like Facebook.

–           Continuously improve our website for you.

–           Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do).

–           Grant us permission to use cookies.

If the settings on your browser that you are using to view this website are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below, however doing so will likely mean that our site will not work as you would expect.

 

How long do cookies last?

When a web server sends a cookie, it asks your browser to keep that particular cookie until a certain date and time. These dates can be:

 

–           Some date in the future – which might be a few minutes or a few hours from now (to track something like your shopping cart in an online store). The cookie might expire many years in the future, to keep track of your browser for a long time.

–           When you close your browser – this is called a session cookie, the next time you start your browser these will have vanished.

–           Some date in the past – this is how the server asks a browser to remove a previously-stored cookie.

 

Our own cookies

We use cookies to make our website work including:

–           Remembering if you have accepted our terms and conditions.

–           Allowing you to add comments to our site.

–           Remembering if we have already asked you certain questions (e.g. you declined to use our app or take our survey).

–           There is no way to prevent these cookies being set other than to not use our site.

 

Site improvement cookies

We regularly test new designs or site features on our sites. We may do this by showing slightly different versions of our websites to different people and anonymously monitoring how our site visitors respond to these different versions. Ultimately this helps us to offer you a better website experience.

 

Anonymous visitor statistics cookies

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using, how long they spend on the site, what page they look at, etc. This helps us to continuously improve our website. These analytics programs also tell us, on an anonymous basis, how people reached this site (e.g. from a search engine) and whether they have been here before, helping us to develop our services for you. Our site uses the following analytics programs:

 

Google Analytics

Advertising or targeting cookies

These types of cookies are used to deliver adverts which will be more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of the advertising campaign. They are normally placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Targeting or advertising cookies will often be linked to site functionality provided by the other organisation.

 

We use ‘Advertising’ cookies on our website to:

 

Link to social networks, like Facebook, who may use information to provide targeted advertising to you on other websites.

Used to identify that you have visited our website, to show you relevant adverts from us.

Provide advertising networks with information on your visit so that they can present you with adverts that you may be interested in.

Social website cookies

So you can easily ‘Like’ or ‘Share’ our content on social network sites, we have sharing buttons on our site. The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.

 

Turning cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so, however, will likely limit the functionality of ours and a large proportion of the world’s websites as cookies are a standard part of most modern websites.

 

This Policy was last updated on the 23rd May 2018