Date last reviewed and approved by Trustees: 6 July 2020
Introduction
This policy sets out how we collect, process and hold your personal data if you visit one of our websites or otherwise provide personal data to us. Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in our possession or likely to come into our possession. The processing of personal data is governed by the Data Protection Act 2018 (DPA 18) and EU General Data Protection Regulation (the “GDPR”).
We are Living Out, a Charitable Incorporated Organisation registered with the Charity Commission in England and Wales (Charity Number 1165572). Our registered office is The Emmanuel Meeting House, Lewins Mead, Bristol, BS1 2NN. We are the data controller of your personal data.
This policy will be reviewed by the trustees annually.
This policy affects your legal rights and obligations so please read it carefully. If you have any questions, please contact info@livingout.org.
Types of personal data we collect
We may collect and store names and contact information, links to organisation, payment information, photographs and video. When we collect this information we will process and store this data in compliance with the relevant legislation. No personal information will be used for publicity without explicit consent being obtained (I.e. the use of quotes, photographs etc.).
How we collect and process personal data
Living Out is committed to collecting, storing, processing and using personal data in compliance with the GDPR and other relevant legislation.
We collect, process, store and use a variety of personal data:
- We may collect your name, address, telephone number, photographs, email address, payment information and information about the organisation you represent when you contact us through our website or directly by email, telephone or post, book a ticket for, or while attending one of our events, donate or make payment through our donation or payment service provider, and through other forms of interaction.
- We may also collect personal data that you give to us about other people if you register them to attend an event. You agree that you have notified any other person whose personal data that you provide to us of this privacy notice and, where necessary, obtained their consent so that we can lawfully process their personal data in accordance with this policy.
- We also collect and hold personal data including name, address, telephone number, photographs, email address, national insurance number, payment information and information about the organisation you represent in relation to our function as an employer, to recruit and manage volunteers, for fundraising, Gift Aid and accounting purposes and activity as an organisation for other regulatory and commercial purposes.
- When you contact us by email or post, we may keep a record of the correspondence and we may also keep a record of any telephone call we have with you.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this. Living Out will take adequate steps to ensure data is accurate and up-to-date.
You do not need to provide us with any personal data to view our website or other internet based services such as events box office. However, we may still collect the information set under the “data we automatically collect” section of this policy.
Opting in to Receive Further Communications
If you opt in to receive further communications from Living Out (such as our newsletter and future events communications) you consent to the processing of your data to send you such communications, which may include newsletters, blog posts, surveys and information about new events. Where consent it relied upon for the collection and retention of data, the option to withdraw consent will be clearly available and evidence of consent will be kept with the personal data.
You can choose to no longer receive communications by contacting us at info@livingout.org or clicking unsubscribe on the email. If you do unsubscribe, it may take up to 5 business days for your new preferences to take effect. We retain your personal data in our records until you notify us that you no longer wish to receive such emails from us.
Data we automatically collect
When you visit our website or other internet based services, we, or third parties on our behalf, automatically collect and store information about your device and your activities. This information could include (a) your computer or other device's unique ID number; (b) technical information about your device such as type of device, web browser or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing actions and patterns. We collect this information using cookies in accordance with the Cookie section of this policy and we use the information we collect on an anonymous basis to improve our website and the services we provide, and for analytical and research purposes.
Legal basis for processing of your personal data
- Processing is necessary for carrying out legal obligations in relation to Gift Aid or under employment, social security or social protection law, or a collective agreement;
- Processing is carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided: -
- the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and
- there is no disclosure to a third party without consent.
- Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and keep you informed about our events.
Who do we share your data with?
Living Out will never share personal information with third parties for profit.
We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, event ticketing providers, email communication providers, IT service providers, accountants, auditors and lawyers.
Under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or protect a third party's rights, property, or safety.
Where we hold and process your personal data
Our website hosting facilities are based in the UK. Some other service providers used for the administration of our business may transfer and store some or all of your personal data outside of the European Union (the EU) for any reason. We shall only transfer your personal data to organisations that have provided adequate safeguards in respect of your personal data.
Cookies
A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.
Google Analytics
We use Google Analytics on our website. The information gathered relating to our website is used to create reports about the use of our website. Google Analytics places several persistent cookies on your computer's hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.
Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: identify cookies.
Some of our service providers such as our event booking service use cookies so that they can recognise you when you return and personalise your settings and preferences. Most browsers are initially set up to accept cookies. You can change your browser settings either to notify you when you have received a cookie, or to refuse to accept cookies. Please note that some of our website services may not operate efficiently if you refuse to accept cookies.
Mouseflow
This website uses Mouseflow: a website analytics tool that provides session replay, heatmaps, funnels, form analytics, feedback surveys, and similar features/functionality. Mouseflow may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, pages visited and content, time on site, browser, operating system, device type (desktop/tablet/phone), screen resolution, visitor type (first time/returning), referrer, anonymized IP address, location (city/country), language, and similar meta data. Mouseflow does not collect any information on pages where it is not installed, nor does it track or collect information outside your web browser. If you'd like to opt-out, you can do so at https://mouseflow.com/opt-out. If you'd like to obtain a copy of your data, make a correction, or have it erased, please contact us first or, as a secondary option, contact Mouseflow at privacy@mouseflow.com.
For more information, see Mouseflow’s Privacy Policy at https://mouseflow.com/legal/company/privacy-policy/
For more information on Mouseflow and GDPR, visit https://mouseflow.com/legal/gdpr/.
For more information on Mouseflow and CCPA/VCDPA visit https://mouseflow.com/legal/ccpa.
Microsoft Clarity
We also use Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising.
For more information about how Microsoft collects and uses your data, visit https://privacy.microsoft.com/en-GB/privacystatement
Security
Living Out will use modern software and appropriate security to ensure your data remains secure.
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. All information you provide to us is stored on our secure servers. Any payment transactions are encrypted using SSL technology.
Where we have given, or you have chosen a password, you are responsible for keeping this password confidential.
However, you acknowledge that no system can be completely secure. Therefore, although we take these steps to secure your personal data, we cannot promise that your personal data will always remain completely secure.
Your rights
Unless subject to an exemption under the DPA 18 / GDPR, you have various rights. These rights are complex but for convenience have summarised them as follows:
- to obtain from us a copy of the personal data that we hold for you,
- to require us to correct errors in the personal data if it is inaccurate or incomplete,
- to require that we delete your personal data where it is not necessary for us to retain such data,
- to withdraw consent to process,
- to, in certain specific and limited circumstances, data portability, restriction on further processing and objection to processing, and
- to lodge a complaint with the Information Commissioners Office (see below)
To exercise these rights, or any other rights you may have under applicable laws, please contact us on info@livingout.org
Living Out has a small staff team, but we are committed to responding to all requests or queries regarding personal data within a timely manner. We aim to respond to any data protection queries or requests within one month. Although it may be longer in certain circumstances.
If you have any complaints in relation to this policy or otherwise in relation to our processing of your personal data, please do let us know as we would like to resolve any issues with you. Please contact us on info@livingout.org. If you do not feel we are dealing with your issue appropriately you should contact the UK supervisory authority: the Information Commissioner, see www.ico.org.uk.
Our website and other services may contain links to other sites of interest. Once you have used these links to leave our site, you should note that we do not have any control over that other site. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this policy. You should exercise caution and look at the privacy policy applicable to the site in question.
Retention
We will only keep your information for as long as it is necessary to provide the services requested and to meet our legal and regulatory requirements. Given the variety of types of interaction we have resulting in personal data it is not possible to specify in advance the periods for which your personal data will be retained. In general the maximum period we retain data is seven years after our last interaction unless it cannot be deleted for legal or technical reasons.
Details of our data retention schedule can be found in our archiving policy. The retention of personal data will be reviewed annually.
General
If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
This policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.
We may change the terms of this policy from time to time by publishing a new version on our website. You are responsible for regularly reviewing this policy so that you are aware of any changes to it.
If you have any queries or concerns about how we use your data, please do get in contact with us using the email address info@livingout.org.