Website privacy and cookies policy
Everyone working for Listening Ear (Merseyside) has a legal duty to keep information about clients confidential.
We have a leaflet explaining why we collect information and the ways in which it is used. It is available to download here.
1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3 How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include name, contact details, contact preferences and payment information, including your willingness to opt into gift aid schemes. The source of the service data is Listening Ear. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating/ trading with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.7 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
3.8 We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely [our interest in the proper administration of our website and business.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4 Providing your personal data to others
4.1 We may disclose personal data including name, contact details, contact preferences and payment information to our suppliers or subcontractors insofar as reasonably necessary in order to fulfil a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.2 Financial transactions relating to our website and services are handled by our payment services providers, Stripe, GoCardless and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at:
- Stripe (URL https://stripe.com/gb/privacy)
- GoCardless (URL https://gocardless.com/legal/privacy/)
- Paypal (URL https://www.paypal.com/ie/webapps/mpp/ua/privacy-full)
4.3 Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:
- Your data will be made available to our website provider
- The data that may be available to them include any of the data we collect as described in section 3 above.
- Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
- They will store your data for a maximum of 7 years.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5 Retaining and deleting personal data
5.1 This Section 5 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 data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email.
7 Your rights
7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee currently fixed at GBP 10; and
(b) the supply of 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).
7.2 We may withhold personal information that you request to the extent permitted by law.
7.3 You may instruct us at any time not to process your personal information for marketing purposes.
7.4 In practice, you will usually either 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.
8 Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
9 Updating information
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
10 About cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11 Cookies that we use
12 Cookies used by our service providers
13 Managing cookies
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
13.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13.3 If you block cookies, you will not be able to use all the features on our website.
14 Our details
14.1 This website is owned and operated by Listening Ear (Merseyside).
14.2 We are registered in England and Wales under registration number 5999650, and our registered office is at St Nicholas Centre, 70 Church Road, Halewood, L26 6LB.
14.3 Our principal place of business is at St Nicholas Centre, 70 Church Road, Halewood, L26 6LB.
14.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
15 Data protection officer
15.1 Our data protection officer’s contact details are: Jayne Hobin-Wright, St Nicholas Centre, 70 Church Road, Halewood, L26 6LB.
16.1 If you have a complaint about us, or the treatment of your data, you can contact the Charity Commission. The Charity Commission is the independent watchdog for charities. You can make a complaint about a charity on their website at www.charity-commission.gov.uk.
16.2 If you have a complaint about our fundraising activities you can also complain to the Fundraising Standards Board (FRSB). To find out whether a charity is an FRSB member and how to go about making a complaint, go to the FSRB public website at www.givewithconfidence.org.uk