This policy was last amended on 19 May 2023.
1. IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
Controller name: Initiative Earth, Charity no. 1192512
Trading as: EcoResolution; Earthed; Initiative Earth.
Activity: Responsible for the overall integrated website, including all charitable activity, fundraising, membership, ambassador, advocate and supporter schemes, courses and learning materials, recruitment of staff.
Controller name: Earthed Works Ltd, Company no. 14794208
Activity: Responsible for sponsorship activities.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO.
DPO contact details
Amy Birch, Finance Manager
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Where any part of this policy becomes invalid or inappropriate due to these changes, it will be the provision within the relevant regulation that will apply in place of it and it will not affect the remaining terms.
Your duty to inform us
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Where we operate a social media page or channel and it is identified that we have a responsibility for your personal data as either a controller or joint-controller with that social media website, we will make this clear to you via a privacy notice.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (known as anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a) Identity Data includes first name and last name. We may ask for further identity data (such as title, marital status, data of birth and gender) but only in situations where we believe this is essential to delivering the service in question.
b) Contact Data includes billing address, delivery address, correspondence address, email address and telephone numbers.
c) Financial Data includes bank account and payment card details.
d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
e) Technical Data includes internet protocol (IP) address, your login data, 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.
f) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
g) Usage Data includes information about how you use our website, products and services.
h) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
i) Still and moving images includes footage and photographs taken at our events at which you might be present and visible. Where this takes place there will be clear signage indicating such with further information as required.
Special Categories (of Personal Data)
Other than as part of our recruitment process, we do not collect any Special Categories of Personal Data about you (this includes details 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). Nor do we collect any information about criminal convictions and offences.
For more information on the Special Categories of Personal Data collected as part of a recruitment process, please refer to the privacy notice provided to you at that time.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with tickets for an event, or goods you have purchased). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; make a donation; attend events at which your image might be captured in film or still image; enter a competition, promotion or survey; or give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: Technical Data from the following parties: (a) analytics providers (such as Google) (b) advertising networks (c) search information providers; Identity & Contact Data from publicly available sources such as social media (when you engage with our Facebook pages, Twitter accounts, or Youtube channel); Identity, Contact, Transaction and Profile Data from publicly available sources (such as wiki pages, publications, etc) as part of an effort to better understand our supporter networks and inform fundraising strategies. Where information is received or likely to be received from third parties or publicly available sources, we will communicate this to you at the earliest opportunity through either a privacy notice or other communications.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we will only rely on consent as a legal basis for processing where no other lawful basis exists. This will include the sending of unsolicited general marketing (i.e. marketing not related to an existing relationship or a previous interaction with us) or third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by reviewing your contact preferences in your Account.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we might use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please check the privacy notices supplied to you or contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new member||(a) Identity(b) Contact(c) Marketing and Communications preferences||(a) Performance of a contract with you|
|To process and deliver your membership service including:(a) Manage payments, fees and charges||(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications preferences||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover membership fees due to us)|
|To enable you to partake in a competition or complete a survey||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications preferences||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how members use our products/services, to improve how we work)|
|To administer and protect this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests (for running our membership services, provision of administration and IT services, network security, to prevent fraud(b) Necessary to comply with a legal obligation|
|To deliver relevant website content to you and measure or understand the effectiveness of how we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications preferences(f) Technical||Necessary for our legitimate interests (to study how members use our products/services, to develop them, and to inform our marketing strategy)|
|General marketing to you (when no other basis or relationship exists)||(a) Identity(b) Contact||With your consent (supplied by you either through an electronic form or similar mechanism)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of members for our products and services, to keep our website updated and relevant, to develop our activities and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile||Necessary for our legitimate interests (to develop our products/services and our membership)|
|To use data analytics to segment our database and gain a better understanding of our supporters to inform our fundraising activity||(a) Identity(b) Transaction||Necessary for our legitimate interest to inform our fundraising strategy and develop relationships with our supporters.|
|Supplementary information from third party and public sources to better understand our supporters (providing nothing is prohibiting us from legally doing so).||(a) Contact(b) Transaction(c) Profile||Necessary for our legitimate interest to inform our fundraising strategy and develop relationships with our supporters.|
|To process an application for employment (via an application form)||(a) Identity Data(b) Contact Data(c) Profile Data||Usually carried out with your consent. A comprehensive privacy notice will be supplied to you at the point of application or soon after.|
|(Filming and photography where you might be identifiable) Within printed publicity and digital content on our website and social media channels.||(i) Still & Moving Images||If photography takes place this will be clearly advertised by signs at the venue. The basis for processing will be either:(a) necessary for our legitimate interestOr (if imagery includes minors who are identifiable)(b) With the explicit consent of a leg|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Through your Account, we have provided an area containing personal data control mechanisms.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased tickets, goods or other services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any organisation outside Initiative Earth for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into your Account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions, or any non-marketing related communication with you.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and either explain the legal basis which allows us to do so, or request your consent to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Section 1 of this Policy.
- Specific third party service providers whose systems may be used for the processing of your personal data, including:
(a) currently we do not use specific third party service providers who process personal data.
- Other External Third Parties as might be required by law
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
If we ever work with a third party service provider (which would be named in section 5 above) based outside the European Economic Area (EEA), their processing of your personal data would involve a transfer of data outside the EEA.
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we will use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield [CM1] (or similar) which requires them to provide similar protection to personal data shared between the Europe and the US.
Please Contact us if you want further information on the specific mechanism used by us if we were in the position of transferring your personal data out of the EEA.
7. KEEPING YOUR DATA SECURE
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. HOW LONG DO WE KEEP YOUR DATA?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ within section 9 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
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 data we hold about you corrected, though we may need to verify the accuracy of the new data 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. Note, however, 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 processing of your personal data where we are relying on a legitimate interest (or those 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 data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the 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 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 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 contact our DPO in the first instance (firstname.lastname@example.org).
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.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month of verification of your identity. 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 at the earliest opportunity and keep you updated.
LAWFUL BASIS FOR PROCESSING
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means asking an individual for their permission to process their personal data, offering them real choice and control. It requires a positive action from the individual.
Data Controller is an entity that determines the purposes, conditions and means of the processing of personal data. Controllers have a legal obligation to give effect to the rights of Data Subjects. This includes the obligation to ensure that the rights of the individual are upheld at all times.
Data Processor is a natural or legal person, authority or agency or any other which processes personal data on behalf of the Controller. Data Processors are obliged to act only under the instructions of the Data Controller, comply with the Controllers’ obligations and assist the Controller with regards to Data Subject rights and handling any requests.
Data Subject is a living individual who is the subject of the personal data.
See also: website Terms & Conditions