52 Lives

Website Privacy Policy 

1. INTRODUCTION

This privacy notice aims to give you information about how we collect and process your personal data through your use of this website, including any data you may provide through this website when, for example, you sign up to receive our email newsletters, offer help, make a nomination or sign up to fundraise.

If you are a child please speak to your parent or guardian before submitting any information via this website and ask them to read and explain this privacy notice to you.

It is important that you read this privacy notice.

Data Controller

52 Lives is a registered charity in England and Wales (1166238) and is the controller and responsible for your personal data (collectively referred to as 52 Lives, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights relating to your personal data, please contact the DPO via dataprotection@52-lives.org.uk or by post to PO Box 3154 Reading RG1 9AT.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with any concerns before you approach the ICO so please do contact us in the first instance.

Changes to the Privacy Notice and / or Your Data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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.

2. YOUR PERSONAL DATA

Personal data is any information about an individual, from which that person can be identified. It does not therefore include data where the identity has been removed (anonymous data).

Depending on your interactions with us, we may collect, use, store and transfer different kinds of personal data which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Nominations includes information provided via the nominations page on our website. It will therefore include all information that is provided to us, including contact details for the nominator and nominee and all information provided about the nomination, including Sensitive Personal Data.
    • We do not collect or process financial data. All financial data is collected and processed by Charity Checkout. Please refer to the Privacy Terms on the donations page.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    Depending on the information provided in a nomination or other contract we may collect Sensitive Personal Data (also known as ‘Special Categories of Personal Data’) about you from our website, (this 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). It is unlikely that we will collect any information about criminal convictions and offences. If you submit a nomination you will be provided with a privacy notice explaining how we process the personal data you provide.

    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with support).

    3. HOW DO WE COLLECT YOUR PERSONAL DATA?

    We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and other Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • nominate someone for our services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from: (a) analytics providers (such as Google based outside the EU); (b) search information providers Identity and Contact Data from publicly availably sourcessuch as Companies House and the Electoral Register based inside the EU.

    4. HOW WE USE YOUR PERSONAL DATA

    We will only use personal data when the law allows us to. Most commonly, we will use personal data in the following circumstances:

  • Where we need to do so to evaluate nominations and subsequently to perform any contract we enter into.
  • 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 basis for processing personal data collected form the website. If we progress a nomination we will issue a separate privacy notice and request appropriate consents. If consent is not given we may be unable to progress the nomination.

    We set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that 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 contact us 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 including basis of legitimate interest

    To register you as a nominator or nominee or contact of 52 Lives

    (a) Identity

    (b) Contact

    (c) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests

    To evaluate and process your nomination

    (a) Identity

    (b) Contact

    (c) Financial

    (d) Transaction

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests

    To manage our relationship with you

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary to comply with a legal obligation

    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    To enable you to engage in a prize draw, competition or complete a survey

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

    To administer and protect our charity and this 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 charity, provision of administration and IT services, network security to prevent fraud

    (b) Necessary to comply with a legal obligation

    To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (f) Technical

    Necessary for our legitimate interests (to study how people use our services, to develop them, to grow our charity and to inform our marketing strategy)

    To use data analytics to improve our website, services, marketing, relationships and experiences

    (a) Technical

    (b) Usage

    Necessary for our legitimate interests (to define types of nominees and contacts for our products and services, to keep our website updated and relevant, to develop our charity and to inform our marketing strategy)

    To make suggestions and recommendations to you about services that may be of interest to you

    (a) Identity

    (b) Contact

    (c) Technical

    (d) Usage

    (e) Profile

    Necessary for our legitimate interests (to develop our products/services and grow our business)

    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 we need to use your personal data for an unrelated purpose, we will notify you.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    5. MARKETING

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

    Information and Promotional Offers

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. You will receive communications from us if you have requested information from us or if you provided us with your details when you made a nomination or entered a competition or registered for a promotion provided that you have not opted out of receiving that marketing.

    Third Party Marketing

    We do not share your personal data with any company outside of 52 Lives for marketing purposes.

    Opting Out

    You can ask us to stop sending you marketing messages at any timeby contacting us or by following the opt-out links on any marketing message sent to you.

    Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

    6. DISCLOSURES OF YOUR PERSONAL DATA

    We may have to share your personal data with the parties set out below for the purposes set out in the table in above.

  • External Third Parties (see Glossary).
  • Specific third parties such as the people we work with to try and deliver the aims and support of the charity.
    • We only disclose information on a need to know basis and require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    7. INTERNATIONAL TRANSFERS

    We do not normally transfer personal data obtained via this website outside the European Economic Area (EEA). If we do need to transfer your personal data, for example, in order to progress a nomination we will issue you with a privacy notice explaining the information to be transferred and the protections that will be applicable.

    8. 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. 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.

    9. 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.

    Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

    Please note that we are required to retain some information for 6 years in order to comply with legal and regulatory requirements.

    In some circumstances you can ask us to delete your data and in others we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

    10. YOUR LEGAL RIGHTS

    You have rights under data protection laws in relation to your personal data, including to:

  • Request access to your personal data (known as a subject access request or SAR) – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of your personal data - This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request that we erase your personal data - This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data - of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request that we restrict the processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent to us processing your personal data - where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


    • If you wish to exercise any of the rights set out above, please contact our Data Protection Officer by email on: dataprotection@52-lives.org. 

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

    In order to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights) we may need to request specific information from you. 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.

    11. GLOSSARY

    This section explains the terminology used above. If you have further questions please contact us.

    Legitimate Interest means the interest of 52 Lives in conducting and managing the operation of the charity to enable us to deliver our aims and objectives. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

    External Third Parties means

  • Service providers acting as processors based in the UK who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Details of any other third parties.