ETC of PWD Privacy Policy for users of our website

 

Information We Collect About Visitors to Our Site

We collect information about visitors to our Site in a few different ways:

  • we collect certain information that the visitors provide to the Site
  • we collect some information automatically

Information a Visitor Provides to a Site

Information that visitors provide directly to a Site primarily happens when visitors type into a text field on a Site, like a comment field or a sign-up form.

Here are the most common ways in which a visitor directly provides information to our Site:

  • Follower and Subscriber Information:When a visitor signs up to follow or subscribe to our Site using WordPress.com, we collect the sign-up information requested by the Site, which typically includes an email address.
  • Site Comments: When a visitor leaves a comment on our Site, we collect that comment, and other information that the visitor provides along with the comment, such as the visitor’s name and email address.

We don’t currently sell through our Site, but should that change in the future then this would apply:

  • Order and Shipment Information: If a visitor orders something from the Site using store and ecommerce features available through WordPress.com we may collect information to process that order, such as credit card and billing information, and an address for shipping the package along to the recipient and calculating applicable taxes.
  • Small Onsite Donations are currently processed through PayPal, ETC of PWD will only receive minimal information about the donor: name/ email address/ home address.
  • Other Information Entered on the Site: We may also collect other information that a visitor enters on the Site, such as a contact form submission, a search query,

Personal data that we process

The following table explains the types of data we collect and the legal basis, under current data protection legislation (GDPR 2018), on which this data is processed.

Purpose

 Data (key elements)

Basis

Enquiring about our organisation and its work

 Name, email, message Legitimate interests:

it is necessary for us to read and store your message so that we can respond in the way that you would expect.

Subscribing to email and or blog/ newsletter updates about our work

 Name, email Consent:

you have given your active consent.

Making a donation

 Name, email, address, Legitimate interests:

this information is necessary for us to fulfill your intention of donating money and your expectation of receiving a confirmation message.

NB: The donation is handled through a Third Party (Paypal) ETC of PWD does not receive or handle any other information but amount/ name/ email address.

Visitor Interactions

 We collect information about a visitor’s interactions with a Site, including the “likes” and “ratings” left by visitors to a Site using WordPress.com. Legitimate interests:

we collect information to understand and respond to the concerns/ interest of our visitors and to clarify the purpose of the charity.

Location Information

 We collect and use Stats information provided by the WordPress.com to, for example, find out how many people visit our Sites/s from certain geographic regions, Legitimate interests:

we collect information to understand and refine the reach of the charity’s message: UK and Uganda most obviously.

Website Functionality

 Website activity collected through cookies

Legitimate interests:

– it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process.

How we use your data

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table above.

For example, we may use your personal information to:

  • reply to enquiries you send to us;
  • handle donations or other transactions that you initiate;
  • where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.

NB: We may also use and share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify any individual (See for example Location Information above).

Cookies & usage tracking

  • A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
  • Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website.

Third Party analytics:

We do not currently use a third party to processing data on our behalf, but should that change, we would put in place a data processing agreement with that third party to fulfil our legal obligations in the use of third party data processors. In that case, Google Analytics would be the system used:

  • Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users’ computers.
  • The information collected by Google Analytics about usage of our website is not personally identifiable.
  • The data is collected anonymously, stored by Google and used by us to create; reports about website usage.
  • Google’s privacy policy is available at:

 http://www.google.com/privacypolicy.html.

How We Share Visitor Information

As a matter of policy, ETC of PWD does not share your information with any third party unless you have provided your explicit consent for us to pass data to a named third party, or we are required by law to share your data. But we may have to share information in the limited circumstances spelled out below:

  • Legal Requests: We will only disclose Site visitor information in response to a subpoena, court order, or other governmental request.
  • To Protect Rights, Property, and Others: We may disclose Site visitor information when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of ETC of PWD or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
  • Information Shared Publicly: Information that visitors choose to make public is disclosed publicly. Information like visitor comments and “likes” are all available to others, including information about the visitor that is displayed in connection with a comment or “like” (such as a visitor’s WordPress.com username and Gravatar). Public information may also be indexed by search engines or used by third parties.

 

How Long We Keep Visitor Information

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.

Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.

 

Rights you have over your data

You have a range of rights over your data, which include the following:

  1. Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example ‘unsubscribe’ links).
  2. You have the right to ask for rectification and/or deletion of your information. You have the right of access to your information.
  3. You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.

A full summary of your legal rights over your data can be found on the Information Commissioner’s website.

Individuals have the right to know what data we hold on them, why the data is being processed and whether it will be given to any third party. They have the right to be given this information in a permanent form: a subject access request. ICO guidance on handling subject access requests.

If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us by making a subject access request on the subject access request page.