1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we may obtain elements of the contact data from the relevant social media account provider.
2.3 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.4 We may process data about your use of our website (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data will be an analytics tracking system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website, the processing of donations, the processing and fulfilment of event bookings, generating invoices, and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Publications – We may process your data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.4 Relationships and communications – We may process your contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
3.5 Direct marketing – We consider “marketing” to mean context-specific information and communications that we might send to you in a format such as a newsletter or other emails for which we may use Mailchimp, an online marketing platform operated by The Rocket Science Group LLC, to send you such information on our behalf. We may process your contact data, account data and/or transaction data for the purposes of creating and sending direct “marketing” communications by email for “marketing”-related purposes. The legal basis for this processing is our legitimate interests, namely promoting Yorkshire Rewilding Network and communicating “marketing” messages to our website visitors and service users.
3.6 Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.7 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.8 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 Your personal data held in our website and “marketing” databases will be stored on the servers of our hosting services providers identified at www.fasthosts.co.uk and www.mailchimp.com.
4.3 We may disclose your personal data such as name and contact information to our suppliers or subcontractors insofar as reasonably necessary in relation to your attendance and participation in events and activities that we might run from time to time.
4.4 Financial transactions relating to our website and services may be handled by our payment services providers, such as for the purposes of transacting donations and/or subscriptions. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in the United Kingdom.
5.3 One of the “marketing” service providers we may use for the purposes of issuing communications to you on our behalf such as, but not limited to, newsletters, is situated in the United States of America. Mailchimp is an online marketing platform operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States of America. Its servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. Mailchimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. They are committed to subjecting all Personal Information received from EEA member countries, United Kingdom, and Switzerland, respectively, in reliance on each Privacy Shield Framework, to each Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view their certification, visit the U.S. Department of Commerce’s Privacy Shield website available at https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active. Mailchimp is responsible for the processing of Personal Information that they receive under each Privacy Shield Framework and subsequently transfer to a third party acting as an agent on their behalf. Mailchimp complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EEA, United Kingdom, and Switzerland, including the onward transfer liability provisions. You can review Mailchimp’s privacy statement at https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) contact data will be retained for as long as you remain subscribed to receive our “marketing” communications and any other subscription services that we may provide;
(b) account data will be retained for as long as you remain subscribed to an account through which we may provide services to you;
(c) transaction data will be retained for as long as we are required to for taxation, audit, and legal reporting purposes;
(d) communication data will normally be via email, including as sent using our Contact Us form on our website, and will be retained for a minimum period of 1 month following the date of the communication in question, and for a maximum period following that date of 3 years, unless the nature of the communication is exceptional and thus will be retained for a period that reflects the nature of the communication.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Your rights
7.1 In this Section 7, we have listed the rights that you have under data protection law.
7.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy.
9. Our details
9.1 This website is owned and operated by VeeringNorth.
9.2 VeeringNorth is a [limited company] registered in England & Wales. Registered Number [tbc].
9.3 Our principal place of business is at [tbc].
9.4 You can contact us:
(a) by post, to [tbc];
(b) using our website contact form; or
(c) by email, using info@veeringnorth.com