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1928 PROJECT WEBSITE PRIVACY POLICY
Last
Updated: 5 May 2020
- WHO ARE WE?
www.1928project.org.uk
is a website (referred to as the “Site”)
operated by Wordsearch
Communications Ltd on
behalf of The 1928 Project.
Personal information collected via the Site will be received by
Brockton Everlast Management Limited ("we"
"us"
or "our"),
which is the controller of the personal information collected on the
Site.
WHAT
IS THIS DOCUMENT AND WHAT PERSONAL INFORMATION DO WE COLLECT FROM
YOU?
We
process certain information about you when you visit the Site. Some
of that information may enable you to be identifiable (“Personal
Information”).
This Website Privacy Policy explains how we process that Personal
Information.
We
collect Personal Information relevant to the activity you choose to
undertake on the Site. This includes:
General
correspondence
If
you correspond with us, we will process and store your name, contact
information and e-mail address.
Technical
and statistical information
We
collect some technical and statistical information about your use of
the Site, including:
the
internet protocol address used to connect your computer or device to
the internet.
your
browser type and version, time zone setting, browser plug-in types
and versions, operating system and platform (as applicable to the
device you are using).
information
about your visit, including the website that referred you to the
Site (if applicable), the path that you take through and from the
Site (including date and time), pages that you viewed or searched
for, page response times, download errors, length of visits to
certain pages, page interaction information (such as scrolling,
clicks, and mouse-overs), and methods used to browse away from the
page.
This
technical and statistical information is typically anonymous but may
identify you in certain circumstances (“Technical
Data”).
Where it does, we treat it as Personal Information.
Our
service provider Google Analytics also collects Technical Data from
you in the course of providing anonymous information to us about the
use of the Site. You can read more about how Google Analytics uses
Technical Data here:
https://support.google.com/analytics/answer/6004245?hl=en-GB
HOW
DO WE USE INFORMATION COLLECTED FROM YOU AND THE LEGAL BASES ON
WHICH WE PROCESS YOUR INFORMATION?
Your
Personal Information may be processed in the following ways:
to
process a donation to The 1928 Project;
to
improve the Site to ensure that content is presented in the most
effective manner;
to
protect us against threats such as fraud or cyber-attacks; and
to
create anonymous data for use in the course of our business, for
example to see which parts of the Site are most popular. Once
anonymised, this data will no longer identify you and so will cease
to be Personal Information.
The
lawful bases we rely on to process your Personal Information are that
it is:
WHO
DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We
may share your Personal Information with Imperial Health Charity and
our service providers as part of the operation of our business (for
example, to enhance the functionality of our services, to obtain
information necessary to reply to your correspondence or to process
enquiries) or to pursue our legitimate interests.
We
may also share your Personal Information with other organisations or
individuals when we have a good-faith belief that it is reasonably
necessary to:
meet
any applicable law, regulation, legal process or enforceable
governmental request;
enforce
applicable legal terms and conditions or our other legal rights,
including investigation of potential violations;
detect,
prevent, or otherwise address fraud, security or technical issues;
or
protect
against or prevent harm to the rights, property or safety of, us,
our personnel or the public as required or permitted by law.
We
require all third parties to respect the security of your Personal
Information and to treat it in accordance with data protection
legislation. We do not allow our third party service providers to use
your Personal Information for their own purposes and only permit them
to process your Personal Information for specified purposes and in
accordance with our instructions.
WHERE
IS YOUR PERSONAL INFORMATION STORED AND PROCESSED?
We
will process and store your Personal Information in our IT systems,
which includes cloud hosted IT systems. We employ organisational and
technical methods to protect your Personal Information, and require
that our service providers do the same.
We
store your Personal Information in the United Kingdom, but in some
circumstances, we may transfer Personal Information that we collect
from you to third party data processors, vendors or hosting partners
acting on our behalf located in countries outside of the EEA or to
other entities in our group of companies in connection with the
purposes set out above. Where we transfer Personal Information to a
country which has not been deemed to provide adequate data protection
standards we always have security measures and approved model clauses
in place to protect your personal information in accordance with this
Website Privacy Policy.
HOW
LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We
will keep your Personal Information for as long as reasonably
necessary to fulfil the purposes described in this Website Privacy
Policy or as we reasonably need to in order to meet our legal and
governance obligations.
To
determine the appropriate retention period for Personal Information,
we consider the amount, nature, and sensitivity of the Personal
Information, the potential risk of harm from unauthorised use or
disclosure of your Personal Information, the purposes for which we
process your Personal Information and whether we can achieve those
purposes through other means, and the applicable legal requirements.
LINKS
TO OTHER WEBSITES
This
Website Privacy Policy does not cover any links within the Site
linking to other websites. Clicking on those links or enabling those
connections may allow third parties to collect or share information
about you. We do not control these third-party websites and are not
responsible for their privacy statements. We encourage you to read
the privacy statements on the other websites you visit.
CHANGES
We
revise this Website Privacy Policy from time to time and you are
responsible for checking this Website Privacy Policy when you visit
the Site. We will use information in accordance with the privacy
policy under which the information was collected. Please check for
any updates to this Website Privacy Policy when you access the Site
again.
YOUR
RIGHTS
Data
protection legislation provides you with certain rights when it comes
to the processing of your Personal Information, which are set out
below
-
Rights
|
What
does this mean?
|
The
right to be informed
|
You
have the right to be provided with clear, transparent and easily
understandable information about how we use your Personal
Information and your rights. This is why we are providing you
with the information in this Website Privacy Policy.
|
The
right of access
|
You
have the right to obtain access to your Personal Information (if
we are processing it), and other certain other information
(similar to that provided in this Website Privacy Policy).
This
is so you are aware and can check that we are using your Personal
Information in accordance with data protection law.
|
The
right to rectification
|
You
are entitled to have your Personal Information corrected if it is
inaccurate or incomplete.
|
The
right to erasure
|
This
is also known as ‘the right to be forgotten’ and, in
simple terms, enables you to request the deletion or removal of
your Personal Information where there is no compelling reason for
us to keep using it. This is not a general right to erasure;
there are exceptions.
|
The
right to restrict processing
|
You
have rights to ‘block’ or suppress further use of
your Personal Information. When processing is restricted, we can
still store your information, but may not use it further. We keep
lists of people who have asked for further use of their Personal
Information to be ‘blocked’ to make sure the
restriction is respected in future.
|
The
right to data portability
|
You
have rights to obtain and reuse your Personal Information for
your own purposes across different services.
|
The
right to object
|
You
have the right to object to certain types of processing,
including processing for direct marketing (which we will do only
with your consent).
|
We
are committed to protecting your privacy. However, if you are not
happy with how we collect or process your Personal Information or
want further information on your rights, you can contact us at the
email address and postal address set out above.
If
you are not satisfied with our response to your complaint or believe
our processing of your Personal Information does not comply with data
protection law, you can make a complaint to the Information
Commissioner’s Office (ICO).
CONTACTING
US
You
can contact us about this Website Privacy Policy at:
Chief
Operating Officer
Brockton
Everlast Management Limited
89
Wardour Street
London
W1F 0UB
Email:
compliance@brocktoneverlast.com