This is the privacy policy of Transformed International. In this document, “we”, “our”, or “us” refer to Transformed International.

They are based on a set written by Net Lawman and released under licence. They protect your rights as well as ours.

We are Transformed International, a charity registered in England and Wales, number 1062561. Our address is Wayside, 34 Burton Road, Neston, Cheshire, UK. CH64 9RA.

Please read this privacy policy carefully and save it.

Introduction

This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.

We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.

We do not share, or sell, or disclose to a third party, any information collected through our website.

1. Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed and ensuring compliance of other applicable data protection legislation.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, David Serle at david.serle@transformedinternational.org

2. Data we process

We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:

• Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
• Your contact information includes information such as mailing address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
• Your financial data includes information such as your bank account and payment card details.
• Transaction data includes details about payments or communications to and from you and information about charitable donations you have made to us.
• Technical data includes your internet protocol (IP) address, 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.
• Your profile includes information such as your username and password, charitable donations made by you, your interests, preferences, feedback and survey responses.
• Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
• We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. For example, we may aggregate profile data to assess interest in a product or service. However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.

3. Special personal information

Special personal information is data 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.

We do not collect any special personal information about you.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

4. Information we process because we have a contractual obligation with you

When you create an account on our website (not currently available), make a charitable donation, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes.
• provide you with relevant information, news and projects updates.

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

5. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our charity, including news and project information and campaigns, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

We will continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at david.serle@transformedinternational.org or by managing your communication preferences by clicking the link at the bottom of our emails.

6. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means.
• whether processing (or not processing) might cause you harm.
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our
• responding to unsolicited communication from you to which we believe you would expect a response.
• protecting and asserting the legal rights of any party.
• insuring against or obtaining professional advice that is required to manage organisational
• protecting your interests where we believe we have a duty to do so.

7. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

8. Information provided on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

• posting a comment.
• clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks.

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at david.serle@transformedinternational.org.

9. Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

10. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of Virgin Giving, a reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

11. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

12. Communicating with us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our organisation.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

13. Complaining

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

14. Charity partner information

This is information given to us by you in your capacity as a charity partner.

It allows us to recognise visitors and charitable donations that you have referred to us.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any charity partner to agree to reciprocate this policy.

Use of information we collect through automated systems when you visit our website

15. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies (see below). They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use our website.
• to record whether you have seen specific messages we display on our website.
• to keep you signed in our site.
• to record your answers to surveys and questionnaires on our site while you complete them.
• to record the conversation thread during a live chat with our support team.

These are the cookies our website uses:

16. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.          

17. Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information

18. Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

19. Data may be processed outside the European Union

Our websites are hosted in the United Kingdom.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly, data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or in Australia.

We use the following safeguards with respect to data transferred outside the European Union:

• the processor abides by the same binding corporate rules regarding data processing.
• both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information.

Control over your own information

20. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes. You can manage your communication preferences by clicking the link at the bottom of our emails.

21. Access to your personal information

At any time you may review or update personally identifiable information that we hold about you. To do so click on the manage preferences link at the bottom of our emails.

To obtain a copy of any information that is not provided on our website you should contact us to make that request.

After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

22. Removal of your information

If you wish us to remove personally identifiable information from our website, you should contact us to make your request.

23. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

24. Use of site by children

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.

We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.

Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.

25. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

26. Data security

We will ensure that the following measures are taken to with respect to the storage of personal data in order to keep your personal data safe and secure.

• All electronic copies of personal data will be stored securely using passwords and data encryption.
• Any hardcopies of personal data, along with any electronic copies stored on physical or removable media will be safely stored in a locked box, drawer, cabinet, or similar.
• All personal data stored electronically will be regularly backed up and all backups will be encrypted.
• No personal data will be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the charity or otherwise without the formal written approval of the Data Protection Officer. Where such approval is required, strict instructions and limitations will be given, and for no longer than is necessary.
• No personal data will be transferred to any device personally belonging to an employee.
• If personal data is being viewed on a computer screen and the computer in question is left unattended for any period of time, the user must lock the computer and screen before leaving it.
• All passwords used to protect personal data will be changed regularly and must contain a combination of uppercase and lowercase letters, numbers, and symbols to limit the risk of passwords being compromised. Under no circumstances should any passwords be written down or shared.
• When personal data is erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

27. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested.
• to comply with other law, including for the period demanded by our tax authorities.
• to support a claim or defence in court.

28. Data breaches

All data breaches will be immediately reported to the Data Protection Officer.

If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours of a data breach having been reported.

29. How you can complain

If you are not happy with our privacy policy or if you have any complaint then you should tell us.

If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

30. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

31. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.

This Privacy Policy shall be deemed effective as of 1^st April 2019 and have been approved and authorised by:

Name: David Serle

Position: Communications Director, Transformed International

Date: 1^st January 2020