Privacy Policy – last updated May 2018
- Introduction1.1 We are committed to safeguarding the privacy of our website visitors and in-store customers; in this policy we explain how we will treat your personal information.
1.2 We will ask you to consent to the storage and use of your personal information in accordance with the terms of this policy when submitting any forms on our website or providing personal information in store.
1.3 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. - Collecting Personal Information2.1 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 this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths). This is to help improve and monitor our website and services;(b) information that you provide to us when registering with our website (including your name and email address);
(c) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(d) information that you provide to us for the purpose of marketing communications (including address for postal communication and telephone numbers, for both phone calls and SMS notifications);
(d) information relating to any purchases you make of our goods or donations of goods, in our stores, on our website or on our eBay store (including your name, delivery address, payment address, telephone numbers, email address and card details where applicable);
(e) information relating to any monetary donations both in our stores and on our website (including your name, address, email address and card details where applicable);
(f) information relating to the delivery of any goods purchased in our stores, on our website or on our eBay store (including your name, delivery address, payment address, telephone numbers, email address and card details where applicable);
(g) information relating to volunteer enquiries (including your name, address, telephone numbers, email address, date of birth and any support needs);
(h) information relating to a Business Enquiry (including name, address, telephone numbers and email address);
(i) information contained in or relating to any communication that you send to us (including the communication content and metadata associated with the communication);
(j) information given to us in store or online for the purposes of gift aid (including name, address, telephone numbers, email address);
(k) information given to us via the ‘Gone for Good’ app for the purposes of donating items (including name, address and telephone numbers);
(l) information given to us for Fundraising purposes (including name, address, telephone numbers, email address and profile image on our website); and
(m) any other personal information that you choose to send to us.
2.2 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.
- Personal Data of Children3.1 Our website and services are expected to be targeted by persons over the age of 13.3.2 If we have reason to believe that we hold personal data of a person under that age, such data will be deleted.
- Using Personal Information4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.4.2 We may use your personal information to:(a) administer our website and business;
(b) enable your use of the services available on our website;
(c) send you goods purchased through our website, in any of our stores or on our eBay store;
(d) send you non-marketing commercial communication;
(e) send you email, phone, sms or post notifications that you have specifically requested;
(f) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter by emailing info@emmaussouthwales.org.uk);
(g) send you marketing communications relating to our business which we think may be of interest to you, or 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);
(h) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(i) deal with enquiries and complaints made by or about you relating to our website;
(j) keep our website secure and prevent fraud;
(k) verify compliance with the terms and conditions governing the use of our website;
(l) to send to HMRC for the purposes of Gift Aid; and
(m) to collect goods that you have chosen to donate to us on our website, by telephone or by the ‘Gone for Good’ app.
4.3 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 unless you have specifically chosen to.
4.4 All our website financial transactions are handled through our payment services provider, Stripe and GoCardless. You can review the provider’s privacy policy at https://stripe.com/gb/privacy and https://gocardless.com/legal/privacy/. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.5 All in store transactions are handled through our payment services provider, Veriphone and SagePay. You can review the provider’s privacy policy at https://www.verifone.com/legal and https://www.sagepay.co.uk/policies/privacy-policy. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.6 All transactions via eBay are handled through PayPal. You can review the provider’s privacy policy at https://www.paypal.com/ee/webapps/mpp/ua/privacy-full. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.7 Raising IT also have access to personal information that is submitted through our website. You can review their privacy policy at https://www.raisingit.com/privacy-and-cookies-policy.
- Disclosing Personal Information5.1 We may disclose your personal information to any relevant staff members, officers, insurers, professional advisers, agents, suppliers or subcontractors in so far as reasonable necessary for the purposes set out in this policy. Your personal information stored on our website is also accessible to Raising IT.5.2 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 reasonable 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 or order disclosure of that personal information.
(e) to our couriers, Royal Mail and myHermes when you have purchased goods on our website or our eBay store.
(f) to HMRC where you have submitted your information for Gift Aid purposes.
5.3 Except as provided in this policy, we will not provide your personal information to third parties.
- Retaining Personal Information6.1 This Section 6 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.6.2 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.6.3 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent 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).
6.4 If purchasing through our eBay store your data will be held by eBay for the length of time indicated in their privacy policy.
6.5 If providing a profile image for fundraising or for your account on our website, such image will be kept in our database for up to 12 months before being manually deleted.
- Security of Personal Information7.1 We will take technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.7.2 We use GoDaddy to host our website. As a result, any information submitted to our website is stored in GoDaddy Servers. You can view GoDaddy’s Privacy Policy here; https://uk.godaddy.com/agreements/ShowDoc.aspx7.3 All electronic financial transactions entered both through our website and instore will be protected by encryption technology. Emmaus South Wales employees cannot view your card details.
7.4 We have taken all steps necessary to ensure that any information transmitted through our website is encrypted and fully protected by using a SSL certificate on all areas of our website.
7.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
7.6 Information submitted to us in store or via telephone for the purposes of Volunteering or Business Interests is likely to be held on Emmaus South Wales’ server. This server is firewalled, encrypted. The server is also Cloud Backed-up, this is also firewalled and encrypted.
7.7 Information submitted to us in store or via telephone for the purposes of item donations or delivery of items is stored on our EPoS system, Kudos. This is accessible to staff members. You can view Kudos privacy policy at http://logodev11.logodev.co.uk/wp-content/uploads/2017/08/Privacy-Policy-Kudos-PLL-231116.pdf
7.8 Information submitted to us in store or via telephone for the purposes of Gift Aid will be stored on our EPoS system, Kudos. This is accessible to staff members. This information may also be passed on to HMRC.
7.9 Information submitted to us online for the purposes of Gift Aid will be stored on our website, this is accessible only to relevant staff members and Raising IT. This information may also be passed on to HMRC.
7.10 Information submitted to us through our website for the purposes of delivery of small items will be stored on our website, this is accessible only to relevant staff members and Raising IT. This information will also be passed on to our couriers, Royal Mail or myHermes for delivery. You can view their privacy policy at https://www.royalmail.com/privacy-policy/ and https://www.myhermes.co.uk/privacy-policy.html
7.11 Information submitted to us online for the purposes of delivery of large items will be stored on our website and on our EPoS system Kudos. This is accessible to staff members and Raising IT.
7.12 Information submitted to us by the ‘Gone for Good’ app for the purposes of item donation will be stored on ‘Gone for Good’ servers. You can view their privacy policy at https://goneforgood.org.uk/privacy-policy/ .
7.13 Information submitted to us for purchases through our eBay store are stored and processed on eBay servers located in the United States. You can view their privacy policy at https://pages.ebay.co.uk/help/policies/privacy-policy.html
7.14 Information passed onto our courier myHermes, for the delivery of small items purchased through our website and through our eBay store are stored on myHermes servers which are located outside of the European Economic Area (“EEA”).
7.15 Payment information submitted through our eBay store is stored and processed by PayPal. This information is stored on servers which are located in the United States and elsewhere in the world where PayPal facilities are located.
- Amendments8.1 We may update this policy from time to time by publishing a new version on our website.8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.8.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].
- Your Rights9.1 Under certain circumstances, by law you have the right to:(a) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.(b) Request correction of the personal information we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
(c) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
(d) Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
(e) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
(f) Request the transfer of your personal information to another party.
9.2 You may instruct us to provide you with any personal information we hold about you; there is no charge for this but provision of such information will be subject to:
(a) the supply and 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)].
9.3 We may withhold personal information that you request to the extent permitted by law.
9.4 You may instruct us at any time not to process your personal information for marketing purposes.
9.5 In practice, you will need to 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 at any time by emailing info@emmaussouthwales.org.uk
- Third party websites10.1 Our website includes hyperlinks to, and details of, third party websites.10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Updating Information11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.