Soul of Africa is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Soul of Africa collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our mailing list, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Soul of Africa Ltd and Soul of Africa Charitable Trust are the controllers and responsible for your personal data (collectively referred to as “Soul of Africa”, “we”, “us” or “our” in this privacy notice).
Soul of Africa Ltd is 100% subsidiary of the Soul of Africa Charitable Trust.
Our details are:
Full name of legal entity: Soul of Africa Limited and Soul of Africa Charitable Trust
Email address: email@example.com
Postal address: 32, The Square, Gillingham, Dorset, SP8 4AR
You have the right to make a complaint at any time 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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 25 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make an order or donation through our website;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
By continuing to browse our site, you consent to our placing cookies on your computer (unless you have chosen to disable them via your browser.
However, if you do not allow cookies on your computer you may not be able to shop our site.
We will ensure your confidential information is kept safely. We may pass your personal data to other companies to support our business operations or for legal or audit purposes only. Your contact details, including email address, will not be shared, sold or rented for any other purpose without specific prior permission from you.
WHAT ARE COOKIES?
Cookies are small, usually randomly encoded, text files that help you to navigate through a website. They are generated on the sites that you visit as well as by third-parties that websites work with to manage key elements of their business. In most cases, they do not involve or use personal information in any way. You can prevent, control and delete cookies on your computer by using the relevant settings within your browser options. The Help menu on the toolbar of most browsers will tell you how to prevent your browser from accepting cookies. This may affect the overall experience that you get from our website.
These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers, such as Google based inside the EU.
- advertising networks Facebook based inside the EU.
- contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Third party organisations
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by clicking on the unsubscribe link which is included in all direct marketing emails.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We aim to be clear when we collect your data and not to do anything you wouldn’t reasonably expect.
We may process your personal data because it is necessary for the performance of a contract. For example, if you make a purchase, sign up for an event or give a donation.
We aim to communicate with you about the work that we do in ways that you find relevant, timely, respectful, and never excessive. To do this, we use data that we have stored about you, such as products that you bought, as well as any contact preferences you may have told us about.
We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may opt out of receiving these at any time using the contact details at the end of this policy.
In the case of email, we will provide you with an option to unsubscribe in every email that we send you. Alternatively, you can use the contact details at the end of this policy or update your contact preferences in your online account with us.
As part of our service to you, we may contact you by email or telephone to provide essential information related to your purchase and donation.
We may process personal data because it is in our legitimate interests to do so. For example, we may use your personal information to understand your reasons for donating to us, to better understand your interests, to carry out screening on potential donors and to conduct due diligence on major donors, to tailor our communications to you and/or to give you an exceptional customer service.
We may also collect information about how you use our services (including our website) to analyse our customer base and improve our processes. Soul of Africa also records and uses film, photographs and audio for promotional purposes on its website, social media accounts and other formats under its legitimate interests basis for processing where it would not be necessary, appropriate or practicable to obtain your specific consent (for example, we may seek specific consent for prominent or impactful uses, but typically not for group shots, background inclusion or internal use).
We may also process your personal data (including sensitive personal data) where:
- it is necessary for medical purposes (for example, in a medical emergency)
- it is necessary to protect your or another person’s vital interests
- we have your consent to do so.
We will also ask for your consent to provide you with information about products and services and fundraising activities which may be of interest to you (apart from where it is appropriate for us to rely on our legitimate interests to do so).
Soul of Africa as a charity / fundraising
Soul of Africa Charitable Trust is registered with the Charity Commission in England and Wales (registration number: 1140567).
We ask for philanthropic support in order to help us carry out our charitable purposes.
We are grateful for the support we receive and many of our supporters tell us that they want to hear from Soul of Africa about information, events and updates that are of interest to them.
You can opt in to receive information about supporting Soul of Africa by opting into receive information from us on our website or by talking to one of our team. You can also get in touch by emailing firstname.lastname@example.org and can change your preferences at any time.
We use third party providers to process some donations, such as Pay Pal and Just Giving. We work with these providers because they provide secure online financial transaction facilities. Use of these services is covered by their own privacy policies. Soul of Africa does not keep any card details for our supporters.
Under our legitimate organisational interest, we may contact you by post, or occasionally by telephone, to seek your support for our charitable activities. Additionally, and only if you have given your consent, we may contact you by email to ask for your support.
Other processing activities
To ensure that our communications are relevant to you and your interests and to assess your likely ability to make, and interest in making, donations to Soul of Africa, we will use information that you have provided to us.
We may combine this with publicly available information about you such as geographical information and measures of affluence where available from external sources to assist us, and publicly available data from social media sites, in order to help us communicate in a relevant way with you.
We may use profiling techniques or third-party organisations to provide us with information about you that will help us to communicate in a relevant way with you, in particular when we are approaching you about potential philanthropic support. Such information is compiled using publicly available data about you.
You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy or email email@example.com.
Please note however that before seeking or accepting major donations we are required to conduct a minimum level of due diligence, including reviewing publicly available personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services] from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of Soul of Africa for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at firstname.lastname@example.org
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your details to third parties
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
- To our service providers such as VIVOBAREFOOT Ltd who process data on our behalf and on our instructions. We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
- Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
- We may share anonymised personal information with other organisations, who use this to analyse our audience development, sales and self-generated funding to better understand our customers. We will always ask for your consent to pass on personal data to other organisations.
We do not sell personal details to third parties for any purpose.
Some of our third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at email@example.com .
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org .
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the 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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
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.