Last Updated: 17 October 2022
Effective Date: 17 October 2022
This Privacy Policy describes the policies of Lullaby Africa, Westholme, Park Lane, Otterbourne, Winchester SO21 2HY (email: info@lullabyafrica.org) on the collection, use and disclosure of your information that we collect when you use our website www.lullabyafrica.org (the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.
We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.
WHAT INFORMATION DO WE COLLECT?
We collect personal information when it is needed to fulfil a service for you, for example, when you make a donation, request information, sign up for an event or otherwise voluntarily provide your personal details. We collect the information you provide, which may include your name, e-mail address, home address and/or telephone number.
You are not required to provide personal data to us. Note, however, that your failure to do so may affect our ability to provide the services you request. For example, we are unable to update you about events if you do not give consent for us to use your contact information for this purpose.
INFORMATION COLLECTED BY VISITING OUR WEBSITE
When visiting the Lullaby Africa website, we follow standard practices and may use features which collect your IP address and data on which pages you are visiting on our site. Similarly, as for many websites, we may also issue cookies to enable certain features to function properly, track traffic or improve user experience in other ways. Cookies place certain information on your device to allow this to happen. This allows us to tailor your experience to what we think you want to see. See our Cookie Policy for more information.
INFORMATION COLLECTED FROM THIRD PARTIES
We use third party sites (e.g. CAF, Givey, Mailchimp, Eventbrite) to enable you to sign up for events, access our services or donate to our charity. We will store any information that they collect from you and pass onto us in order to provide the service you are signing up to. If you have concerns, you may wish to check their privacy policies to find out more information on how they will process your data.
INFORMATION COLLECTED BY Lullaby Africa PERSONNEL (INCLUDES REPRESENTATIVES, VOLUNTEERS, STAFF AND TRUSTEES)
As you interact with the Lullaby Africa team, there will be occasions where we will collect and store basic personal information which you have given to us through them. These details may be shared within Lullaby Africa, but only for the purposes you gave the information in the first place.
If you wish to be added or removed from our database you can contact info@lullabyafrica.org.
LEGAL BASIS
We store and process data for the primary purpose of achieving our charitable purposes as set out in the Introduction of this Privacy Policy.
The lawful bases for processing data are defined as:
(a) Consent: you have given clear consent for us to process your personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract we have with you.
(c) Legal obligation: the processing is necessary for us to comply with the law.
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for us to perform a task in the public interest.
(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party.
Where the data is provided for financial support, we store and process your data in order to comply with current charitable and financial legislations, such as processing donations and claiming the related Gift Aid. This is a legal obligation.
Where the data is provided in exchange for a service, for example, ordering materials, we store and process your data to fulfil the contract you have made with us.
WHAT DO WE DO WITH YOUR INFORMATION?
PROCESSING OF REQUESTS / DONATIONS
We may use the personal data we collect to do one or more of the following:
Process donations you give us, including claiming gift aid;
Provide information or materials you have requested;
Keep you up to date on news and stories about our activities and work;
Ask for financial and non-financial support, such as volunteering or prayer;
Keep records of your relationship with us, e.g. questions you have asked.
APPLYING FOR A JOB OR VOLUNTEERING WITH US
Where you provide personal data and sensitive personal data when applying for a job with us, we will process, store and disclose the personal data we collect to:
Support the recruitment process;
Answer any questions you may have;
Use third parties to provide services such as references.
Where you provide personal or sensitive personal data, such as dietary requirements, mobility requirements or health information, we will store, process and disclose the personal information we collect to:
Deliver the volunteering opportunity, including the disclosure of sensitive data, such as medical information;
Provide the administration of these events or opportunities to serve;
Use third parties to provide services such as references and criminal referencing, such as DBS checks;
Provide appropriate support;
Answer any questions or feedback you may have.
HOW AND WHERE DO WE STORE YOUR INFORMATION?
HOW LONG WE STORE YOUR INFORMATION
We will keep your personal information only for as long as we consider it necessary to carry out each activity. We take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned.
For example, we will retain details of donations for up to 10 years to meet tax and accounting requirements.
SECURITY
We ensure that we have in place appropriate controls to protect any personal data you provide. We ensure that access to personal data is restricted only to those personnel whose roles require such access and that suitable training is provided for these people.
We may make limited use from time to time of external companies to process personal data on our behalf. For example, we may use CAF to receive donations. When we do use external companies, we remain responsible for the storing and processing of your personal data. We do not store credit card details.
WHERE WE STORE YOUR PERSONAL INFORMATION
We store the data you provide in our password-protected cloud databases (e.g. Microsoft OneDrive, Mailchimp).
Some of our service providers (e.g. Mailchimp) lie outside of the European Economic Area (EEA). Therefore, sometimes we transfer your data outside the EEA. These agents are bound by contract to protect your data and we remain responsible for their actions. For a copy of their safeguards, please contact us at info@lullabyafrica.org.
We take all reasonable steps to ensure that your data is stored and processed securely, whether in electronic or hard copy formats, and is protected from unauthorised access, use or disclosure.
WITH WHOM DO WE SHARE YOUR INFORMATION?
REGULATORY BODIES
We may need to pass on information if required by law or by a regulatory body, for example, as part of a Gift Aid audit by HMRC or if asked for details by a law enforcement agency.
THIRD PARTIES
We may use third parties to carry out tasks on our behalf, such as receiving donations.
YOUR RIGHTS
Current legislation provides the following rights for individuals in relation to their personal data:
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling.
To find out more about what these rights mean for you, please refer to the Information Commissioner's website: https://ico.org.uk
SEEING YOUR PERSONAL INFORMATION, CHANGING YOUR PERSONAL INFORMATION AND CONSENT PREFERENCES
You can update your personal information and/or change your preferences on what you receive from us, including marketing and fundraising materials, or how we contact you, by mail, email or phone at any time.
DELETING YOUR PERSONAL INFORMATION
You have the right to ask us to delete your personal data, to ask us to restrict our processing or to object to our processing of your personal data. You can do so at any time by writing to us at Privacy Officer, Lullaby Africa, Westholme, Park Lane, Otterbourne, Winchester SO21 2HY. This right covers all data held by us whether centrally or by our Representatives.
Please note that we may need to hold onto data for legal reasons, e.g. financial information for auditing purposes. In these cases, we will store the minimum data required and will delete it as soon as we are able.