Snowdonia Donkeys is committed to protecting your privacy. At all times we aim to respect any personal information you share with us, or that we receive from others, and keep it safe. This Privacy Notice sets out our data processing practices and your rights and options regarding the ways in which your personal information is used and collected.
This Notice contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.
CONTENTS OF THIS POLICY.
- How we collect personal information about you.
- What personal information do we use?
- Do we process special categories of data?
- How and why will we use your personal information?
- Lawful bases.
- Communications for marketing/promotional purposes.
- Children’s personal information.
- How long do we keep your personal information?
- Will we share your personal information?
- Security/storage of and access to your personal information.
- International Data Transfers.
- Exercising your Rights.
- Changes to this Notice.
- Links and third parties.
- How to contact us.
1. HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU:
- When you give it to us directly. When you submitted your adoption form, registering your contact details.
2. WHAT PERSONAL INFORMATION DO WE USE?
We may collect, store and otherwise process the following kinds of personal information:
- your name and contact details including postal address, telephone number, email address and emergency contact details;
- your date of birth and gender.
3. DO WE PROCESS SPECIAL CATEGORIES OF DATA?
The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and religious beliefs.
In certain situations, Snowdonia Donkeys may collect and/or use these types of data. We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.
4. HOW AND WHY WILL WE USE YOUR PERSONAL INFORMATION?
- to register you as an adopter of a Snowdonia Donkey.
- to email you our newsletters and updates;
- to otherwise provide you with services, products or information you have requested;
- to provide further information about our work, services or activities (where necessary, only where you have provided your consent to receive such information);
- to answer your questions/ requests and communicate with you in general;
- to allow you to apply for a job or volunteer role with us;
- to manage relationships with our partners and service providers;
- to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
- to keep our facilities safe and secure;
- to audit and/ or administer our accounts;
- to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
- for the prevention of fraud or misuse of services; and/or
- for the establishment, defence and/ or enforcement of legal claims;
- to contact your next of kin in the event of an accident or emergency;
- in the reporting of dangerous occurrences and incidents to the relevant bodies.
5. LAWFUL BASES.
The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant:
- Where you have provided your consent for us to use your personal information in a certain way (for example, we may ask for your consent to use your personal information to send you email newsletters, or to collect special categories of your personal information. Special categories of personal information are explained in paragraph 2 above).
- Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).
- Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
- Where it is in your/someone else’s vital interests (for example, a medical emergency).
- Where there is a legitimate interest in us doing so.
The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights as an individual).
We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
6. COMMUNICATIONS FOR MARKETING/PROMOTIONAL PURPOSES.
We may use your contact details to provide you with information about our work, events, services and/or activities which we consider may be of interest to you.
Where we do this via email, SMS or telephone (where you are registered with the Telephone Preference Service), we will not do so without your prior consent (unless allowed to do so via applicable law).
Where you have provided us with your consent previously but do not wish to be contacted by us about our work, events, services and/or activities in the future, please let us know by emailing our data protection lead. You can opt out of receiving emails from the Snowdonia Donkeys at any time by clicking the “unsubscribe” link at the bottom of our emails.
7. CHILDREN’S PERSONAL INFORMATION
When we process children’s personal information, where required we will not do so without their consent or, where required, the consent of a parent/ guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care and in accordance with our Safeguarding Children and Vulnerable Groups Policy.
8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove it from our records at the relevant time. For further details please request to see our Data Retention Policy.
If you request to receive no further contact from us, we may keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.
9. WILL WE SHARE YOUR PERSONAL INFORMATION?
We do not share, sell or rent your personal information to third parties for marketing purposes.
10. SECURITY/STORAGE OF AND ACCESS TO YOUR PERSONAL INFORMATION.
Snowdonia Donkeys is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information.
Your personal information is only accessible by appropriately trained staff and volunteers and stored on password protected cloud services or in a secure cabinet.
11. INTERNATIONAL DATA TRANSFERS.
We will not transfer your data internationally.
12. EXERCISING 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 marketing or fundraising purposes or to unsubscribe from our email list at any time. You also have the following rights:
- Right of access – you can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
- Right of erasure – at your request we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete it.
- 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. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.
- Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
- Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests basis (see paragraph 4), (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
- Right to data portability – to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details in paragraph 15 below.
We encourage you to raise any concerns or complaints you have about the way we use your personal information by contacting us using the details provided in paragraph 15 below. You are further entitled to make a complaint to the Information Commissioner’s Office – www.ico.org.uk. For further information on how to exercise this right, please contact us using the details below.
13. CHANGES TO THIS NOTICE
We may update this Notice from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an update notice on our website. This Notice was last updated on 22/05/18
14. LINKS AND THIRD PARTIES.
We link our website directly to other sites. This Notice does not cover external 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. HOW TO CONTACT US
Please let us know if you have any questions or concerns about this Notice or about the way in which the Wall processes your personal information by contacting us at the channels below.