Privacy Notice

Introduction

Transform Europe Network is committed to helping maintain your privacy and deeply appreciates that you trust us with your personal data.

TEN is committed to keeping your personal data safe and treating it confidentially as required by UK legislation including the General Data Protection Regulations. You can exercise your rights including requesting that TEN changes or remove your details at any time.

Who are we?

Transform Europe Network (“TEN”) is the working name for Eurovangelism, whose charity registration number is 1140592 and company registration number is 7507682. TEN is registered as a charity and company limited by guarantee in England and Wales.

TEN is registered with the Information Commissioner’s Office (ICO) as a data controller, registration number ZA482896. You can find out more about our registration here including a list of all data related activities that we have registered with the ICO.

TEN’s registered address is 23 Apex Court, Woodlands, Bradley Stoke, Bristol  BS32 4JT.

For further information about our privacy policy and data protection, please contact the Data Protection Coordinator, James Chilcott:

  • calling on 01179 615161
  • emailing: admin@ten-uk.org
  • writing to the Data Protection Coordinator at TEN, Unit 23 Apex Court, Woodlands, Bradley Stoke, Bristol BS32 4JT

What personal data do we collect and where do we collect it from?

Personal data is any information that can be used to identify you. For example, it can include your name, email address, postal address, telephone number, mobile telephone number, bank account details, credit/debit card details, and whether you are a taxpayer so that we can claim Gift Aid on any donations you may make. It also includes Internet Protocol (IP) addresses (the location of the computer on the internet), details of pages visited on our websites and files downloaded.

We ask for your personal data whenever you directly engage with us. This may be as a donor, an online/offline shopper, a subscriber for news and magazine, a volunteer, an attendee at a TEN event, an employee, a contractor, or someone else with a stated interest in our work.

Collecting personal data helps us to keep in touch, based on your stated preferences, and to provide you with relevant and timely information. We never share your details with third parties outside of TEN’s contractual relationships.

We collect personal data in the following ways:

Information you give us directly:

Sign-up:
The data that we collect when you sign-up online, by telephone, at an event or enter a contract with TEN will include:

  • Your title, name and email address and / or postal address

Additional data may include:

  • The name of the organisation/church you are associated with
  • Your telephone number
  • Your communication preferences
  • Your areas of interest in the work of TEN

Website:
By visiting our website, depending on your browser settings, we will collect technical data. This may include:

  • Your Internet Protocol (IP) address, browser type, type of device or operating system, general location, date stamps, etc. (see Website Security below).

Email:
The technical data that we collect when you read our emails may include:

  • IP address, device type, general location, date stamps, etc.

Information you give us indirectly:

Your data may be shared with us by fundraising sites such as JustGiving, and you should check their privacy notices when you provide your personal data, to understand how they will process your data.

 

Information we collect from your use of our website:

This website www.ten-uk.org has security measures in place to protect against the loss, misuse and/or alteration of the data under our control. We utilise industry-standard HTTPS certificated secure server connections across the website and provide additional encryption during the product ordering and donation process.

Log files – TEN uses log files in its website to track trends, views of content and user activity. This data helps TEN to develop its website to better suit visitor experience and to match your areas of interest. Be reassured that Log files are unable to identify your personal data e.g. name and address. Instead, these log files contain information about what search engine domains (e.g. Google.com) are used, what browser software and system software is used, and what pages are visited on our site. This data may be archived for analysis in the future.

Cookies – Cookies and local storage are industry-standard technologies that allows a website or app to store and retrieve data more efficiently on a person’s computer, mobile phone or other device. While cookies are a short string-based file, local storage can hold larger amounts of data for storage, caching and offline purposes. Like most websites, we use cookies and local storage to provide you with a better, faster or safer experience. Most web browsers offer settings to control whether to allow cookies or local storage. We recommend that cookies and local storage remain turned on to take full advantage of our website.

Links – TEN’s website contains links to other relevant sites. We try to exercise caution in such cases, however, the privacy and data collection practices on linked websites are entirely separate from TEN and are not covered by this privacy policy. The links to other sites on this website are provided as an additional resource only and should not be seen as an endorsement, approval or agreement with any information or resources offered at sites accessed through our site. No inference or assumption should be made and no representation should be inferred that TEN is connected with, operates or controls these websites.

Information from public sources:

We may combine information you provide to us with information available from public sources or records in order to gain a better understanding of our supporters and those who engage with us. This helps us to improve our fundraising methods, resources and programmes. Such information may be found in places such as Companies House and information that has been published online and in print.

Sensitive/special categories of data

Data Protection law recognises that certain categories of personal data are more sensitive. This is known as sensitive personal data or special categories of data and covers health information, race and ethnicity, religious or philosophical beliefs and political opinions amongst other things. We do not collect sensitive personal data about you unless there is a clear reason for doing so, such as involvement in an event where we need this data to ensure safeguarding, to carry out appropriate checks on volunteers, or care for participants. For some events we will collect health information so that leaders on our events have the relevant information to care for participants.

When we collect this information, we will make it clear to you what we are collecting and why and what are our legitimate interests or other legal grounds for processing this information.

Under 16s

TEN does not hold personal data for children below the age of 16 years.

How do we use personal data?

TEN is extremely careful with the collection, storage and processing of personal data you provide. We use it for the following purposes:

  • To keep you informed about the work of TEN
  • To inform you of relevant events organised by TEN
  • To process your purchase of gifts from our online shop
  • To provide you with a receipt and acknowledgement of donations
  • To keep a record for any lawful purpose

TEN will always provide a way for you to be removed from our mailing lists by the magazine Response Slip, email unsubscribe option or when you ask us to do so directly.

TEN never sells, rents or leases personal data. Nor do we exchange any personal data with other organisations.

TEN never publishes the personal data of its supporters to others.

What is our lawful basis for processing data?

We rely on a variety of lawful bases for processing data depending on the purpose of the activity being undertaken.

We ask for your personal data whenever you directly engage with us. This may be as a donor, an online/offline shopper, a subscriber for news and magazine, a volunteer, an attendee at a TEN event, an employee, a contractor, or someone else with a stated interest in our work.

We use a contractual basis for processing data relating to online and offline shopping.

We rely on legitimate interests for a variety of purposes. Legitimate interest is about balancing the interests of TEN against your rights and freedoms and having due regard to your reasonable expectations about the use of your data. These purposes include:

  • mailing you information related to your subscription to news and our magazine, and about related resources and events that you might be interested in, given your previous purchases and attendance
  • thanking those of you who have made a financial gift
  • sharing with you by mail or telephone the fundraising needs of the charity and to ask for your support; you can alter your communication preferences at any time.

We rely on consent for all email marketing communications such as newsletters and fundraising appeals; every email newsletter you receive provides a clear opportunity for you to opt out or alter your communication preferences.

We use compliance with a legal obligation as the basis for processing any legally required activities such as Gift Aid returns to HMRC.

Who has access to your personal data and how do we keep it safe?

TEN is committed to keeping your personal data safe by only using secure, world-class, cloud-based solutions.

All staff and volunteers are fully briefed on TEN’s data protection policies and procedures relevant to their role. Staff only have access to data that they need to be able to carry out their duties.

Passwords

Where you or we have provided a password enabling you to access parts of our websites or use our services, it is your responsibility to keep this password confidential. Please don’t share your password with anyone. If you think anyone else has gained access to your password, please let us know as soon as possible.

Transferring your information outside of Europe

Although most of the data we store and process stays within the UK, some data may be transferred to countries outside the European Economic Area (EEA).

This may occur if, for example, one of our supplier’s servers on which personal data is stored is located in a country outside the EU or if we use a cloud IT platform where data is dispersed between a number of different servers. These countries may not have similar data protection laws to the UK. However, we will ensure that your privacy continues to be protected as outlined in this privacy notice and in accordance with our legal obligations under applicable data protection legislation.

By submitting your personal data to us you agree to this transfer, storing or processing at a location outside the EEA.

Payment by credit or debit card

If you use your credit or debit card to donate to us, buy something or pay online or over the phone, we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard through compliant online virtual terminals managed by  PayaCharity or PayPal. Find out more information about PCI DSS standards by visiting their website at www.pcisecuritystandards.org.

Only those staff authorised to process payments will be able to see your card details. Once your transaction is completed, we will not store your full credit or debit card details.

(A PCI DSS compliant online virtual terminal)

Sharing your information

TEN does not sell or share any data about you to other organisations.

TEN may disclose your personal data only in the following circumstances:

  • To third parties who provide a service to us and are our data processors. We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data (including wealth screening), providing marketing assistance, processing credit card payments, and providing customer service. These data processors have access to personal data needed to perform their functions but may not use it for other purposes. We require these third parties to comply strictly with our instructions and data protection laws and will make sure that appropriate controls are in place.
  • Where we are under a duty to disclose your personal data in order to comply with any legal obligation (for example to government bodies and law enforcement agencies), or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect TEN (for example in cases of suspected fraud or defamation).

How long do we keep your personal data for?

We have a retention policy for every personal data set. We will hold your personal data on our systems for as long as is needed to fulfil the purpose for which we hold the data or as long as is required by law for the relevant activity. For example, HMRC requires us to keep a record of donations, Gift Aid and financial transactions for seven years.

If you request that we stop sending you marketing or fundraising information, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

Where your data is no longer required we will ensure that it is disposed of in a secure manner.

What are you rights and how can you exercise them?

The Data Protection Act and the upcoming General Data Protection Regulation give you certain rights over your data and how we use it. You have the following rights:

  • Informed – this privacy notice
  • Access – you may request a copy of the data we hold about you and details of the purposes for which we process your data (known as a subject access request)
  • Rectification – update or amend the data we hold about you if it is wrong, change your communication preferences at any time or withdraw your consent to use of your personal data where we are relying on consent as the legal ground for processing it
  • Erasure – ask us to remove your personal data from our records
  • Restrict processing – ask us to restrict the processing of your personal data
  • Data portability – obtain a portable copy of certain personal data where this is processed automatically
  • Object – object to the processing of your data for marketing purposes
  • Related to automated decision making including profiling – ask us to explain any automated processing we carry out and the impact of this on you

If you wish to exercise any of these rights, please contact us in any way listed in the ‘Who are we’ section at the start of this privacy notice. We may ask for reasonable proof of your identity before providing you with data or carrying out any of the above actions.

To change your communications preferences, you may find it easier to use the unsubscribe link in the emails we send, or the response slip when we send information by post.

Changes to this statement

TEN reserves the right to make changes to this privacy statement and its associated policies at any time and requests that you review this statement periodically for updates.

 

Last revised on 07/01/2019

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