PRIVACY POLICY

INTRODUCTION

Integrity International Trust Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy sets out how we handle the personal data of our beneficiaries, supporters, donors, volunteers, suppliers, charity partners and other third parties we deal with and applies to our website and to all of our products, services and fundraising and awareness events (together our “Services”).

Personal data, or personal information, means any information about an individual from which that person can be identified. Where an individual cannot be identified, for example when personal data has been aggregated and anonymised, this Privacy Policy does not apply.

We may need to update this Privacy Policy from time to time. Any changes made to this Privacy Policy will be communicated via our website www.integrityinternationaltrust.com.

This Privacy Policy is provided in a layered format so you can click through to the specific sections set out below:

1. WHO WE ARE
2. HOW WE COLLECT DATA FROM YOU
3. THE DATA WE COLLECT FROM YOU
4. HOW WE USE YOUR PERSONAL DATA
5. WHO WE SHARE YOU PERSONAL DATA WITH
6. WHERE WE STORE YOU PERSONAL DATA
7. MARKETING
8. DATA RETENTION
9. DATA SECURITY
10. YOUR RIGHTS
11. CONTACTING US

WHO WE ARE

www.integrityinternationaltrust.com is a website operated by Integrity International Trust Limited. References to ‘Integrity International’, “we”, “us” or “our” in these Terms of Use are to Integrity International Trust Limited.

Integrity International Trust is a registered charity (number 1176502), registered in England and Wales as a company limited by guarantee (number 11121606) whose registered office is at 10 Queen Street Place, London, United Kingdom, EC4R 1BE.

HOW WE COLLECT DATA FROM YOU

When you visit our website or use our Services, we collect personal data from you via four main methods:

Information you provide to us directly: For example, when you post information on our social media pages, make a donation, register for a fundraising event or otherwise provide us with personal information. When you register, we’ll ask for personal information, like your name, email address, telephone number, date of birth, bank account details for setting up a regular direct debit gift and contact preferences.

Information we get from your use of our website and services. We collect information about our online content that you use and how you use it. We are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer. We collect some of this data by using cookies and other similar tracking technologies. Further information about the types of cookies we use and how we use them can be found in our Cookie Policy.

Information from known third parties: We collect most data from you directly but we may receive information about you from our third party partners with whom you choose to interact, for example online third party fundraising websites when making a donation to someone who is fundraising on our behalf. This can include information such as your name, postal or email address, phone number, your geographic location, credit/debit card details and whether you are a tax payer so that we can claim Gift Aid. To the extent that we have not done so already, we (or they) will notify you when we receive information about you from them and tell you how and why we intend to use that information.

Information which is publically available: We may include collect data found in places such as Companies House, LinkedIn and information that appears in published articles.

THE DATA WE COLLECT FROM YOU

Depending on how you interact with us, we may collect, use, store and transfer different kinds of personal data about you including:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data you provide where you make a payment, such as bank details or credit/debit card details (although we don’t store credit or debit card details). Information as to whether you are a tax payer so that we can claim Gift Aid.
• Technical Data includes 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 our website.
• Profile/ Usage Data includes payments you have made to us, IIT events you have attended or participated in, your interests, preferences, feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Sensitive personal data: certain types of personal categories of personal data are regarded by the law as more sensitive than others such as information about your health, ethnic origin, religious beliefs, political opinions or any genetic or biometric data that is used to identify you. We do not usually collect ‘sensitive personal data’ unless there is a clear reason for doing so, such as participation in a sporting event where we need this information to ensure that we provide appropriate facilities or medical support to enable you to participate safely. We may also collect sensitive personal data if you make the information public or if you tell us about your experiences relating to the causes we support. We will always make it clear when we collect this information from you what sensitive personal data we are collecting and why.

HOW WE USE YOUR PERSONAL DATA

We will only ever process your personal data:

1. to perform a contract with you; or
2. where we have legitimate interests to process your personal data and those interests are not overridden by your rights; or
3. in accordance with a legal or regulatory obligation; or
4. where we have your consent.

We use your personal information for a number of purposes including the following:

• to provide you with information, services, products you have requested from us;
• to provide information about our work, activities, volunteering or events but only if you have consented to being contacted for those purposes (unless IIT is able to rely on the legitimate interest basis for contacting you in this regard);
• to process any donations we receive from you and to claim Gift Aid on them where applicable;
• to invite you to fundraising or awareness events;
• for general administration purposes (e.g. to contact you about a donation you have made or the event you have registered for);
• for internal record keeping (e.g. of enquiries, feedback or complaints);
• to use IP addresses to identify your approximate location, to block disruptive use, to record website traffic or to personalise the way our information is presented to you;
• to analyse and improve our website and to make it as user-friendly as possible;
• to conduct supporter research so that we can contact you in the most appropriate way and with the most relevant information.
• to detect and prevent any fraudulent or malicious activity and make sure that users of our website comply with our Terms of Use; and
• for any other specific purposes that you may agree to from time to time.

WHO WE SHARE YOUR PERSONAL DATA WITH

We may need to share and/or process your personal data with third parties. We will only disclose your personal data to:

• third parties who facilitate delivery of our Services;
• to our charity partners who facilitate the deployment of the funds we raise for charitable purposes;
• our professional advisers;
• regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate we will notify you of this type of disclosure;
• other third parties where we have your consent.

WHERE WE STORE YOU PERSONAL DATA

Most personal data collected and processed during the use of any of our Services is stored on servers located in the European Economic Area (“EEA”). Information may be transferred to our other offices and/or to third parties, which may be situated outside the EEA and may be processed by staff operating outside the EEA. When we transfer personal data from the EEA to other countries in which applicable laws do not offer the same level of data privacy protection as in the EEA, we take measures to provide an appropriate level of data privacy protection and such transfers are only made with your express individual consent, and/or for the reason that the transfer is necessary for one of the following reasons:

1. the performance of a contract between us and you;
2. public interest;
3. to establish, exercise or defend legal claims, or to protect your vital interests where you may be physically or legally incapable of doing so; and
4. for our legitimate interests where those interests are not overridden by your rights.

MARKETING

We use your information to send you communications about our work and how you can help us, for example, information about our campaigns, volunteering, fundraising activities and how you can donate to us. Occasionally, we may include information from partner organisations or organisations who support us in these communications where you have consented to her from such organisations.

We rely on your consent for marketing communications by electronic means – including text, email and social media. We rely on legitimate interests for other means of marketing including post and live calls.

You can ask us or to stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by contacting us at hello@integrityinternationaltrust.com.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

You may, at any time, request us to delete your personal data or we may choose to erase the same in cases where we no longer need to process it for one of the reasons detailed in this Privacy Policy.

DATA SECURITY

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.

YOUR RIGHTS

You have rights under data protection laws to:

1. request access to your personal data;
2. request correction of your personal data;
3. request erasure of your personal data;
4. object to processing of your personal data;
5. request restriction of processing your personal data;
6. request transfer of your personal data; and
7. to withdraw your consent.

You can exercise these rights at any time by sending an email to hello@integrityinternational.com .

We try to respond to all legitimate requests within one month. 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 and keep you updated.

You will not usually have to pay a fee to access your personal data (or to exercise any of your 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.

If you are not happy with the way in which we are processing your personal data you have the right to make a complaint 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 at hello@integrityinternationaltrust.com .

CONTACTING US

Please address all questions and comments in relation to this Privacy Policy or the exercise of your rights under it to:

Integrity International Trust Limited
50 Broadway
London SW1H 0RG

Email: hello@integrityinternationaltrust.com