Privacy Notice
We are Thrive UK-Poverty Relief (referred to in this Privacy Notice as we, us and our).
We are a registered charity in England and Wales (number 1194343) and a charitable incorporated organisation in England and Wales with company number CE025452.
Our address is: 58 Emsworth Close, Bury St Edmunds, Suffolk IP32 7LT.
We are the controller of personal data obtained via our website (Site) meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this Privacy Notice carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our Site.
This Privacy Notice also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Given the nature of our Site, we do not expect to collect the personal data of anyone under 14 years old. If you are aware that any personal data of anyone under 14 years old has been shared with our Site please let us know so that we can delete that data.
This Privacy Notice outlines our privacy policy and explains how we may collect and use personal data when you visit our website.
What personal information do we collect?
We will not collect any personal data (personally identifiable information about you such as your name, address, email etc.) unless you provide such information to us, for example; by filling out the “Contact Us” page on this Site or emailing us.
We do automatically collect certain types of non-personally identifiable information relating to your use of this website (for example; relating to the type of browser and operating system which you use).
How do we use this information?
We use non-personally identifiable information to help us understand how our Site is used and to improve the Site. Details of how we collect and use non-personally identifiable information can be found in the Cookie Notice [link].
We will normally only use your personal data in order to respond to any enquiry or other communication from you, or to process any request made by you (e.g. an enquiry about our charity, to be included on a mailing list, receive an invitation for an event etc.).
We may also use personal data to send you information about our charitable activities. If you do not want us to contact you in this way email us at [ ] and put “unsubscribe” in the subject line.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
– where you have given consent;
– to comply with our legal and regulatory obligations;
– for the performance of a contract with you or to take steps at your request before entering into a contract, or
– for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| To respond to you if you contact us through our Site. | Depending upon the circumstance: - your consent; - our legitimate interests. |
| To enforce legal rights or defend or undertake legal proceedings | To comply with our legal and regulatory obligations. Our legitimate interests. |
| Retaining and evaluating information on your recent visits to our Site and how you move around different sections of our Site for analytics purposes. This helps us to understand how people use our Site so that we can make it more intuitive or to check our Site is working as intended | Depending on the circumstances: —your consent as gathered by the separate cookies tool on our Site (see our Cookie Notice); —where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party; i.e. to comply with our regulatory obligations. |
| Communications with you providing information about us and our charitable activities. | For our legitimate interest. |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to our services, or other important notices | Depending on the circumstances: — to comply with our legal and regulatory obligations — in other cases, for our legitimate interests;, i.e. to be as efficient as we can so we can improve and develop our Site and our charity. |
| Protecting the security of systems and data | To comply with our legal and regulatory obligations For our legitimate interests. |
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our charity; e.g. to record and demonstrate evidence of your consents where relevant. | To comply with our legal and regulatory obligations. |
| To obtain feedback on our charity and Site from existing and former users of our Site. | For our legitimate interests; i.e. to improve and develop our charity and the Site. |
| External audits and quality checks,; e.g. for the audit of our accounts and by our regulator | For our legitimate interests or a those of a third party,; i.e. to comply with our legal and regulatory obligations. |
We, or the third parties mentioned above, may occasionally also need to share personal data with:
– external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
– professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations; and
– Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations (such as the Charity Commission).
If you would like more information about who we share our data with and why, please contact us.
How Long do we Keep Your Data?
We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data. Please contact us for further details.
Sharing Personal Information
Personal Information may be shared with our regulator (such as the Charity Commission), our professional advisers and third parties who provide services to us.
If these parties be based in countries outside of the European Economic Area (EEA) this may result in your Personal Information being transferred outside of the EEA, data protection laws may differ outside of the EEA and the data laws in some countries may offer less protection than within the EEA.
If you do not want your Personal Data to be shared in this way email us at [ ].
Whilst unlikely, we may also be compelled to share your Personal Data if required to do so by law or legal process.
What we will not do
We will not sell or rent your personal data to any other company or person.
We will not share your personal data except as described in the section above.
Third Party Websites
Please note that the information contained in this Privacy Notice does not apply to any third party websites accessible through links from this Site and we are not responsible for the such websites. You should read the privacy notice of such websites in order to understand how your personal data and other information will be treated by these websites.
You should also be aware that personal data and other information transmitted over the internet may not be secure and may be collected by others.
Your Rights
You have certain rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to the processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the personal data; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above please email us at [ ].
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner in the UK.
The Information Commissioner may be contacted at HERE or by telephone: 0303 123 1113.
How to Contact Us
You can contact us by post, email or telephone if you have any questions about this Privacy Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are:
write to us at:
Thrive UK-Poverty Relief
58 Emsworth Close
Bury St Edmunds
Suffolk IP32 7LT.
email us: [ ]
