This privacy notice describes how Alabaré, the data controller, collects, uses and protects your information in relation to our Fundraising, Marketing and Retail activities.
This policy was last updated on 12th September 2023, and relates to the Data Protection Act 2018 and the UK General Data Protection Regulation.
How we collect your information
The information we hold about you comes from the way you engage with us, such as: if you donate money; donate items to our shops; purchase items online; access our website; complete our surveys at any of our events; or become involved in any of our campaigns. We may collect information about you online through our website, via email, the post, over the phone or from discussions with you. We will also receive your information from third parties such as JustGiving, Give.Net, Ebay, Facebook, Google, WorldPay and PayPal where you make donations, or from event sites (Eventbrite) or third party event providers that we work with.
Before contacting specific individuals to ask if they would like to support our work we may do some research to understand how likely it is they would be interested. We typically look at information published in the media, the internet and social media. We may also obtain information from public registers or specific organisations such as the Directory of Social Change (Trustfunding) www.governmentfunding.org.uk. If our research shows that a person is unlikely to be interested, we will not contact them, and we will not keep the research.
The type of information we hold
The information we hold may include name, address, age, contact telephone numbers, email address, bank details through regular donations. We may keep records of our meetings, conversations and correspondence with you.
We may also collect details of your visits to our website including traffic data, location data, weblogs and other communications data and the pages that you access. We do this by using Cookies, which you can find out more about below.
To ensure the information we hold is accurate, we may check the accuracy of your contact details against external publicly available lists such as the Fundraising Preference Service, Telephone Preference Service and Mail Preference Service.
How we use your information
We may use your information in the following ways:
- To provide you with information including fundraising or campaigning activities, or events which we feel may be of interest to you where you have consented to be contacted, or where we believe there is legitimate interest*, or where there is a business necessity. If you do not want to be contacted or sent marketing material, please use the unsubscribe link on any email, update your mailing preferences via our website www.alabare.co.uk/keepintouch, or contact us on 01722 346548. 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. We may retain your details on a suppression list to help ensure that we do not contact you for marketing purposes in the future, however we may still need to contact you for administrative purposes. If you request that your details are deleted then we will remove your record completely from our system (providing that we are not required by law to keep it for financial auditing purposes).
- To process donations.
- To deliver any goods or services you have requested.
- To fulfil our statutory obligations, for example the collection of Gift Aid or certain financial transactions, where we are legally required to hold some personal information.
- To allow you to participate in interactive features on our website when you choose to do so, for example we may help you to complete forms by inserting your contact details for you to edit.
- To analyse and improve the services offered on our website by providing you with the most user-friendly navigation experience we can for your computer or other internet devices.
- As a fundraising organisation, we undertake in-house research and from time to time engage specialist agencies to gather information about you from publicly available sources, for example, Companies House, the Electoral Register, company websites, ‘rich lists’, social networks such as Linkedin, political and property registers and news archives. We may also carry out data cleaning or wealth screening to fast-track the research using our trusted third party partners. You will always have the right to opt out of this processing. We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. This may include people connected to our current major supporters, trustees or other lead volunteers. We also use publicly available sources to carry out due diligence on donors in line with the charity’s Gift Acceptance Policy and to meet money laundering regulations. This research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor that is appropriate for you. If you would prefer us not to use your data in this way, please email us at firstname.lastname@example.org.
Under the terms of legitimate interest, we are able to process your personal information if we have a genuine and legitimate reason to do so, and we are not infringing your rights or best interests. We believe that our supporters and those who have shown an interest in our charity (for example donors, events participants, shop donors and volunteers) are likely to want to learn more about the impact their support has on the lives of our beneficiaries, and be made aware of how they can support them in the future.
If we are processing your data under the terms of legitimate interest we will send you communications that are relevant and timely. These communications will enable us to thank our supporters and inform them of the impact of their gifts and keep them updated with future news, campaigns and events. Our legitimate interest processing will never override your preferences. We will always give you the opportunity to update your preferences so that you can choose which of our communications are best suited to your interests.
You can update your mailing preferences at any time by calling us on 01722 346548 or by completing and submitting our keeping in touch form.
For each channel of communication that we use we will process your data in the following ways:
If you have made a donation to Alabaré or one of our shops, volunteered for us, or attended one of our events, within the last 2 years, under the legitimate interest rules we will make the assumption that you are happy to receive our communications, unless you have indicated otherwise. We will always provide you with a clear and easy opt out process in every communication we send you. If you opt out of receiving further information from us, we will retain your records for up to 6 years (from the end of the financial year in which the transaction was made) for HMRC purposes but we will not contact you
If you have donated more than 2 years ago, and have not explicitly indicated that you would like to receive our communications, we will use our legitimate interest balancing assessment before mailing you, to judge whether we believe you would still wish us to send you our communications. You can, of course, update your preferences at any time or let us know if you would like us to stop mailing you. We will retain your records for up to 6 years (from the end of the financial year in which the transaction was made) for HMRC purposes.
If you have opted in to receive our communications, and subsequently made a donation to us, or volunteered or attended an event, we will assume that your consent to our communications has been refreshed at the point of the new interaction. This will apply indefinitely with each positive interaction that you have with us. You can contact us to update your preferences at any time, and we will remind you of this when we contact you.
After receiving a donation from you we may contact you by telephone to thank you, unless you have asked us not to. We may also telephone you from time to time to let you know about events or appeals that we believe you would be interested in, or to seek your feedback on our charity.
If you subscribe via our website to our e-newsletter, or you have provided us with your email address (with consent) when making a donation, signing up to an event or completing on of our surveys, we will send you our e-communications, e.g. e-newsletter.
Every time we send you a marketing email we will give you the opportunity to unsubscribe from our emails. You can also update your preferences at any time by calling us. If you have not unsubscribed from our emails, then we will continue to mail you until such times as you tell us otherwise, or we assess that you are no longer interested in receiving them.
Who we will share your information with
We will not sell or swap your information with any agency or other charity. We will not share personal information about you with third parties without your consent, unless the law allows us to and these organisations are GDPR compliant. We may however share your information with our trusted suppliers and external service providers who could include:
- Our suppliers who are involved in delivering goods to you.*
- Our suppliers who are involved in providing marketing and fundraising services e.g. mailing houses.*
- Our suppliers who manage some of our IT services and web services in order to deliver the contracted services.*
- HMRC for Gift Aid.
- Where you have given us permission to contact you, we may use external services providers to do this on our behalf.*
- We do not sell or share personal details to third parties for the purposes of marketing. However, if we run an event in partnership with another named organisation your details may need to be shared. We will be very clear what will happen to your data when you register.
* Our suppliers and external service providers may only use Alabaré’s data to complete the contracted service.
Storing your information
Your personal information will be stored on systems owned or operated by Alabaré or those of our specific suppliers and will only be stored inside the European Economic Area (EEA) or where such verified Standard Contractual Clauses safeguards are in place. Within Alabaré your information will be stored on our secured systems.
How long we will keep your information for
|Data Type||Mailing List Retention||Record Retention Period||Reason for Retention|
|Information about an individual who has not made a donation, or attended an event without sponsorship||Within three years of receiving your consent and thereafter we will seek reassess your likely interest in receiving our mailings||Until the point our balancing assessment suggests you are unlikely to be still interested in receiving communications from us.||We have obtained consent|
|Information about an individual who has made a donation(s) which was not gift aided||Up to three years based on our legitimate interest processing and/or when we receive your consent* and thereafter if our balancing assessment suggests you are likely to be sill interested in receiving communications from us||Six years from the end of the financial year in which the transaction was made your contact record will be archived||Companies Act /Charities Act & HMRC|
|Information about an individual who has made a donation(s) and gift aided||Up to three years based on our legitimate interest processing and/or when we receive your consent* and thereafter if our balancing assessment suggests you are likely to be still interested in receiving communications from us||Six years from the end of the financial year in which the transaction was made your contact record will be archived||Companies Act / Charities Act & HMRC|
* For more information about legitimate interest please see our ‘How we use your information’
How you can access your information
If you would like a copy of the information we hold about you, please email the Data Protection Lead at email@example.com.
You can request your information be deleted or that we stop using your information. We will comply with your request, but may have to maintain records for legal reasons. If you are not happy with how we are using your information or how we have responded to your request, please do contact us so we can do our utmost to resolve the situation.
We take complaints very seriously but recognise that we sometimes get things wrong. You find out how to make a complaint, and more about how we will look into your complaint by clicking here.
You can of course contact the Information Commissioner’s Office at https://ico.org.uk/ at any time if you would like to discuss any concerns you have about how we have used your personal information.
How will we tell you about future changes to this Privacy Statement
Any changes we make to our Privacy Statement will be available to you on our website. Please check for updates from time to time, so you are always fully aware of what information is collected and how it is used.
How to contact us
If you have any questions or concerns about our use of your personal information please email the Alabaré Data Protection Lead firstname.lastname@example.org.