PRIVACY & COOKIE POLICY

 

1. What This Privacy and Cookie Policy Covers

HeartSWell is committed to protecting your personal information and being transparent about what information we hold, whether you are a donor, volunteer, supporter or campaigner.

Developing a better understanding of our supporters through their personal data allows us to fundraise more efficiently, which ultimately helps to support our beneficiaries in the South West. We have developed this policy to ensure that transparency is at the core of what we do, especially around our policy on profiling and wealth screening (see 'Fundraising' section below).

The purpose of this policy is to give you a clear explanation about how HeartSWell collects and uses the personal information you provide to us and that we collect, whether online, via phone, email, in letters or in any other correspondence or from third parties.

We ensure that we use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:

What information HeartSWell may collect about you;

  • How we will use that information;
  • Whether we disclose your details to anyone else;
  • Your choices regarding the information you provide to us; and
  • How we use cookies to provide services to you or to improve your use of our websites.

If you have any queries about this privacy and cookies policy please contact the Operations Manager at HeartSWell, HeartSWell Lodge, 7 Blunts Lane, Plymouth, PL6 8BE or email: [email protected]

 

2. Who We Are

We are a local heart charity operating in the South West of the UK and our registered charity number is 1092779. We are also registered as a company in England and Wales under registration number 4411852.

 

3. Information Collection

We collect information in the following ways:

3.1 Information you give us:

For example, when you engage with our social media or message boards, make a donation to us, register for an event or otherwise provide us with personal information. When you register, we’ll ask for personal information, like your name, email address and telephone number to store with your account.

3.2 Information we get from your use of our website and services:

We collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our websites or view and interact with our ads and content.

3.3 Information from third parties

We may also receive information about you from third parties. This can include information such as your name, postal address, email address, phone number, your geographic location (for mobile devices), credit/debit card details and whether you are a tax payer so that we can claim Gift Aid.  We, like all companies, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer

Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our websites. See below, under Marketing materials – to understand our purposes for processing your personal information.

Data Protection law recognises that certain categories of personal information are more sensitive. This is known as sensitive personal data and covers health information, race, religious beliefs and political opinions. We do not usually collect ‘sensitive personal data’ about our supporters unless there is a clear reason for doing so, such as participation in a marathon or similar fundraising event or where we need this information to ensure that we provide appropriate facilities or support to enable you to participate in an event.

We may also collect sensitive personal data if you make the information public or if you tell us about your experiences relating to heart disease; however, we will always make it clear to you when we collect this information from you, what sensitive personal data we are collecting and why.

 

4. Website Users

Our HeartSWell website uses cookies to help our websites work well and to track information about how people are using them. More information on cookies can be found further down the page under 'Cookies'.

In addition, if you register on our websites then the following will also apply:

  • The HeartSWell website collects personal information when you register with us.
  • The website you sign up to will collect information such as your name, email address and post code. Once you register with the website you will not be anonymous to us if and when you subsequently sign in.
  • As part of the registration process and continued use of Heartswell services, you agree that any registration information you give to HeartSWell will always be accurate, correct and up to date. Please do get in touch should you need to amend any of your personal information.
  • We collect and retain information about your interactions with us so that we can process your interactions and deal with future queries.
  • We use cookies to allow us to store limited information on an individual’s computer to either track them through tracking cookies or to allow people to have automatic logons as an example. We use this information to provide you with a good experience when browsing our website and to improve the functionality of our site.

 

 

5. Your Debit & Credit Card Information

If you use your credit or debit card to donate to us, buy something or pay for a registration online or over the phone, we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard. You can find our more information about PCI DSS here - https://www.pcisecuritystandards.org/security_standards/index.php

We do not store your credit or debit card details at all, following the completion of your transaction. All card details and validation codes are securely destroyed once the payment or donation has been processed. Only staff authorised and trained to process payments will be able to see your card details.

If we receive an email containing any credit or debit card details, it will be immediately deleted, no payment will be taken and you will be notified about this. All purchases or donations should be completed through the donation page or online shop on our website (www.heartswell.org.uk) or via our customer support centre by calling 01752 315 929.

 

6. Legal Basis & Legitimate Interest

When we collect and use your personal information, we will make sure this is only done in accordance with at least one of the legal grounds available to us under Data Protection law.

One of these is where we have obtained your specific consent to use your information for a previously notified purpose, such as to send you email/text marketing or to provide you with a product, service or information at your request.

Another is where we have a legal obligation to use or disclose information about you – for instance, where we are ordered by a court or regulatory authority or we are legally required to hold donor transaction details for Gift Aid or accounting/tax purposes.

In certain instances, we may collect and use personal information where this is necessary in our legitimate interest as a charity, this includes being able to:

  • send direct marketing material to supporters by post or contacting them by telephone for fundraising purposes (subject to checking against the Telephone Preference Service and any existing marketing preferences). See more at Marketing Materials below;
  • conduct research to better understand who our supporters are and better target our fundraising activity. See more at Fundraising below;
  • monitor who we deal with to protect our charity against fraud, money laundering and other risks;
  • maintain and administer our donor database and systems.

In all cases, we balance our legitimate interests against your rights as an individual and make sure we only use personal information in a way or for a purpose that you would reasonably expect in accordance with this Policy and that does not intrude on your privacy or previously expressed marketing preferences.

Where we process sensitive personal data (as mentioned above), we will make sure that we only do so in accordance with one of the additional lawful grounds for processing such as where we have your explicit consent, or you have made that information manifestly public. When we do this, we will tell you what sensitive personal data we are collecting and why.

7. Marketing Materials

We want to ensure you receive the level of information about HeartSWell that is right for you.

7.1 Email/text marketing:

If you actively provide your consent to us along with your email address and/or mobile phone number, we may contact you for marketing purposes by email or text message. By subscribing to HeartSWell emails or opting in to email communication from HeartSWell, you grant us the right to use the email for both email marketing purposes and advertisement targeting

7.2 Post/telephone marketing:

If you have provided us with your postal address or telephone number, we may send you direct mail or telephone you about our work unless you have told us that you would prefer not to receive such information. We also actively check telephone numbers against the Telephone Preference Service and will only make telephone calls to you where your telephone number is listed on the TPS if you have specifically told us that you do not object to such calls and have consented to receive them.

7.3 Your choice:

It is always your choice as to whether you want to receive information about our work, how we raise funds and the ways you can get involved. If you do not want us to use your personal information in these ways, please indicate your preferences on the form on which we collect your data.

You may opt-out of our marketing communications at any time by clicking the ‘unsubscribe’ link in at the end of our marketing emails sending us an "opt-out" text message, following the instructions we provide you in our initial text.

You can also change any of your contact preferences at any time (including telling us that you don’t want us to contact you for marketing purposes by telephone, or by post) by contacting our Customer Support Centre on 01752 315 929 or [email protected]

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted by us for such purposes. However, we will retain your details on a suppression list to help ensure that we do not continue to contact you.

 

8. Fundraising

We carry out targeted fundraising activity to ensure that we are contacting you with the most appropriate communication, which is relevant and timely and will ultimately provide an improved experience for you. In doing so, we may use profiling techniques or use third party wealth screening companies and insight companies to provide us with general information about you. Such information is compiled using publicly available data about you or information that you have already provided to us.

This activity assists us in understanding the background of the people who support us and helps us to make appropriate requests to supporters who may have the means and the want to give more. You can opt out of your data being used for profiling and wealth screening techniques by contacting [email protected]

 

9. Recipients – Information & Disclosure

HeartSWell may disclose your personal information in the following circumstances:

  • To other HeartSWell entities, trading subsidiaries, suppliers or service providers only to provide the products or services you've requested from our site(s) where, for example, we use a separate company to deliver goods to you.
  • To third parties who provide a service to us and are data processors. This would include our trusted partners that work with us in connection with our charitable purposes, and other entities that act as fundraisers for HeartSWell, sell HeartSWell products or provide HeartSWell information and marketing (subject to your communication preferences and our internal policies and procedures). We require these third parties to comply strictly with our instructions and data protection laws and we will make sure that appropriate controls are in place. We enter into contracts with all of our data processors and regularly monitor their activities to ensure they are complying with HeartSWell policies and procedures.
  • Where we are under a duty to disclose your personal information 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 HeartSWell, for example in cases of suspected fraud or defamation.

Rest assured, we will never share, sell or swap your details with any third parties for the purposes of their own marketing or the monetising of your data.

 

10.  Counselling Support Services

If you contact our service to request counselling support, you may choose to provide details of a personal nature in particular about you or someone else’s health. Only the HeartSWell team and counselling services will use this personal information and only for the purposes of responding to your enquiry. They will not pass the personal information on to anyone else without express permission except in exceptional circumstances to comply with the British Association for Counselling and Psychotherapy code of professional conduct or the law. Your personal information and details of your enquiry will be recorded for quality and monitoring purposes and stored on a secure database. Your details will not be used for marketing purposes. If for any reason you want your details removed from these records, please contact the HeartSWell team on 01752 315 929.

 

11. Under 18s

We are committed to protecting the privacy of the young people that engage with us through our support services for young people on our website, at events and at schools.

Our fundraising events also request specific information about the age of participants. If you are under 18 and would like to get involved, please ensure that you have consent from a parent or guardian before giving us your personal information. When we collect information about a child or young person aged under 18 we will make it very clear as to the reasons for collecting this information and how it will be used.

 

12. Inappropriate Website Content

If you post or send any content that we believe to be inappropriate, offensive or in breach of any laws, such as defamatory content on our forums or social media pages, we may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies.

 

13. Keeping Your Personal Information

We keep your personal information only, for as long as required to operate the service in accordance with legal requirements and tax and accounting rules. Where your information is no longer required, we will ensure it is disposed of in a secure manner.

 

14. Cookies

Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to improve the performance of a website, for saving different options and to provide website owners with information on how the site is being used.

We use cookies to enhance the experience of the websites, to increase the performance, to identify how the website is being used and where we can make improvements and to monitor how our advertisements perform. Some of our cookies are vital for the websites to operate effectively and others are optional but may decrease the usability or performance of the websites.

 

The cookies that we use can be broken into four categories:

(i) Cookies which are necessary to run the website

 Some of our site cookies are essential to run the websites and without the acceptance or use of these cookies the website or elements of the website will not work. These include, but are not limited to:

  • Adding items to a shopping basket
  • Remembering items in a shopping basket if you leave the website

 

(ii) Cookies which are optional

All other cookies are optional and the removal of these cookies may decrease the usability or performance of our websites. Such optional cookies include, but are not limited to:

  • Remembering that you are logged in across our websites
  • Your optional settings
  • Tracking usage of a website

 

(iii) Cookies which ensure value for money

To ensure that we are getting best value for money from our advertisements we may use cookies that track how many people click on the advertisements and subsequent actions which is known as a “click through”.  

(iv) Cookies which are from trusted third parties

We utilise the technology of third parties on a regular basis to ensure that we are using up to date systems which are managed by the best companies to provide us with the information that we need. This in turn means that there will be a number of third party cookies from our trusted suppliers used on our websites. Each company is responsible for the cookies that they place onto your device and have separate policy documents to highlight their use.

 

14.1 What Will Happen If You Disable Some or All of The Cookies That HeartSWell Uses?

If you opt to disable some or all cookies, we are unable to guarantee that our websites will operate.

14.2 How Do I Manage My Cookie Settings?

Internet browsers (such as but not limited to Internet Explorer, Google Chrome, Firefox, Opera or Safari) will allow some control over most cookies through their settings. You will need to refer to the operating manual or review the settings of your browser software to identify what cookies are on your device and how to remove them.

Find out more about cookies and how to manage them. Some third parties may allow you to manage their cookies independently. Please refer to the list of third party providers above and confirm their respective policy pages for further information. 

14.3 Acceptance of Cookie Use

By continuing to use our website you will have been deemed to have agreed to our use of cookies subject to any preferences you may have indicated to us or any overriding browser settings you may have.

 

15. Tracking

We use multiple first and third-party technologies such as pixel tags and web beacons to track and improve the user experience on our sites, quality of service and to monitor the effectiveness of campaigns and digital marketing activity.

We may use them to:

  • see what website content is popular and how people are using the site as they allow us to track users movement through our websites. This type of information is amalgamated so that we can build up a picture of how the site is performing.
  • make sure we offer you a consistent service. For example, if we are testing new website content or we want to run a survey, we use tracking to remember what content you have seen or if you have already been asked to join the survey.

In addition, when we email you, we may place a tag (also known as ‘tracking pixel’) on the email we send out. These let us monitor performance of our emails marketing activity.

15.1 Your Ability to Edit and Delete Your Account Information and Preferences

The accuracy of your personal information is important to us. You can edit your Heartswell account information, including your address and contact details at any time. If you would like to change your preferences or update the details we hold about you other than online, please contact our Customer Support Centre on 01752 315 929 or [email protected]  or write to HeartSWell, HeartSWell Lodge, 7 Blunts Lane, Plymouth, PL6 8BE

15.2 Your Rights to Your Personal Information

Under the Data Protection Act 1998 you have a right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. You also have the right to request us to erase your personal information, request us to restrict our processing of your personal information or to object to our processing of your personal information.

Should you wish to exercise these rights we require you to prove your identity with two pieces of approved identification. Please address requests to the Operations Manager, HeartSWell, HeartSWell Lodge, 7 Blunts Lane, Plymouth, PL6 8BE and we will respond within 40 days, of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records. We reserve the right to charge a fee of £10 for this process.

Where you have provided your consent for our use of your personal information, you always have a right to withdraw your consent at any time.

 

16. Your Ability to Edit & Delete Your Account Information Preferences

The accuracy of your personal information is important to us. You can edit your HeartSWell account information, including your address and contact details at any time. If you would like to change your preferences or update the details we hold about you other than online, please contact our Customer Support Centre on 01752 315 929 or [email protected]  or write to HeartSWell, HeartSWell Lodge, 7 Blunts Lane, Plymouth, PL6 8BE.

 

17. Your Rights to Your Personal Information

Under the Data Protection Act 1998 you have a right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. You also have the right to request us to erase your personal information, request us to restrict our processing of your personal information or to object to our processing of your personal information.

Should you wish to exercise these rights, we require you to prove your identity with two pieces of approved identification. Please address requests to the Operations Manager, HeartSWell, HeartSWell Lodge, 7 Blunts Lane, Plymouth, PL6 8BE and we will respond within 40 days, of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records. We reserve the right to charge a fee of £10 for this process.

Where you have provided your consent for our use of your personal information, you always have a right to withdraw your consent at any time.

 

18. Changes to this Privacy Policy

We may update the terms of this policy at any time, so please do check it from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us or by placing a prominent notice on our website(s). By continuing to use our website you will be deemed to have accepted such changes.

19. Complaints, Compliments or Comments

If you are unhappy with our work or something that we have done or failed to do, we want to know about it. We also welcome your views on what we do well. Your comments enable us as an organisation to learn and continuously improve our services.

Please contact us by phone on: 01752 315 929, by email at: [email protected] by post to: HeartSWell, HeartSWell Lodge, 7 Blunts Lane, Plymouth, PL6 8BE or via our website: www.heartswell.org.uk

 

20. Monitoring & Review

Version

Date

Approved By

Review Date

1.1

Feb 2018

Clem Spencer - Chairman

Apr 2019