1. Introduction

Dame Kelly Holmes Trust understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.damekellyholmestrust.org (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of our site. If you do not accept and agree with this Privacy Policy, you must stop using our site immediately.

2. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings: 

“Account”     means an account required to access and/or use certain areas and features of Our Site;

“Cookie”       means a small text file placed on your computer or device by Our Site when you visit certain parts of  Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 15, below.

3. Information About Us

3.1.1          Our Site is operated by Raising IT on behalf of Dame Kelly Holmes Trust, a limited company registered in England under company number 06531532 and charity number 1128529.

3.1.2          Registered address: South Vaults, Green Park Station, 2-3 Westmoreland Station Road, Bath, BA1 1IB

3.1.3          VAT number:  9484633

3.14           Data Protection Officer: Ben Hilton

                  Email address: [email protected]

                  Telephone number: 020 3167 1874

3.15           Postal Address: South Vaults, Green Park Station, 2-3 Westmoreland Station Road, Bath, BA1 1IB

 

 

4. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

5. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

6. What Are My Rights?

 

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

 

  • The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 16.
  • The right of access to the personal data we hold about you.
  • The right to rectification if any personal data we hold about you is inaccurate or incomplete.
  • The right to be forgotten, i.e. the right to ask us to delete any personal data we hold about you.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for particular purposes.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights with respect to automated decision making and profiling.

 

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Section 16.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

 

7. What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data. Please also see Section 15 on our use of Cookies and similar technologies:

  • name
  • date of birth
  • gender
  • business/company name
  • job title
  • profession
  • contact information such as email addresses and telephone numbers
  • demographic information such as post code, preferences, and interests
  • financial information such as credit / debit card numbers
  • IP address
  • web browser type and version
  • operating system
  • a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to

 

We may also receive information about you from independent third parties, such as fundraising sites like Just Giving or Virgin Money Giving or event organisers such as the London Marathon. We will only receive information from third parties in this way if you have given your consent for your information to be passed on to us. You should check their privacy policy when you provide your information to understand how they will process your information. Once we have obtained this information from the third party it will be covered by our privacy policy as well as by the originating third party.

8. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. If you have applied for one of the Dame Kelly Holmes Trust programmes, we will use your information to run, fund, develop and evaluate our programmes.

If you support us, for example make a donation, volunteer, register to fundraise, sign up for an event we will mainly use your information to:

  • Provide you with the services, products or information that you asked for, as well as information about other services, products or information we think might interest you where you have consented to being contacted;
  • Administer your donation or support your fundraising, including processing Gift Aid;
  • Send you surveys, and for market research;
  • Invite you to events;
  • Keep a record of your relationship with us and record the contact we have with you; and,
  • Ensure we know how you prefer to be contacted.

We may also use personal information to carry out due diligence so that we are fundraising in accordance within the law, the code of fundraising practice and our internal policies and procedures

With your permission, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone] and post with information, news, and offers on our services and programmes which we believe you may be interested in. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

 

9. How Long Will You Keep My Personal Data?

Dame Kelly Holmes Trust must keep all personal data safe and only hold it for as long as is necessary. To comply with the law certain personal data must be retained for a minimum of 6 years.

  • To effectively respond to a question or complaint
  • To fulfil any contractual or legal requirements

Exceptions to this rule are:

  • All special category data will be deleted or irreversibly anonymised within 12 months of the date of the event or programme/intervention for which it was collected.
  • Information that may be relevant to personal injury claims, or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after your interaction with us. It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address, by contacting us on [email protected].

10. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

11. Do You Share My Personal Data?

We are committed to protecting your data and therefore it will never be disclosed or sold to external organisations other than those acting as agents and data processors carrying out work on our behalf. Where we enter into a relationship with an external party, any such arrangements will be subject to a formal agreement between the Trust and that organisation to protect the security of your data. They only act under our instructions and we maintain full responsibility for your data.

Third Parties may include:

  • Suppliers who send out communications on our behalf, such as invitations to our events, for example, email companies like MailChimp;
  • Our Board and Trustees where we share information for internal procedures and policies only. Should we merge with another organisation to form a new entity, your data may be transferred to the new entity;
  • Our delivery partners within the UK or abroad to enable us to deliver our programmes effectively.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

12. How Can I Control My Personal Data?

In addition to your rights under the GDPR, set out in section 5, when you submit personal data via Our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details.

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 

13. Can I Withhold Information?

You may access Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

 

14. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it where any such personal data is held. This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 16. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ for example, if you make repetitive requests a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

15. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt which asks you to accept cookies to use the website as intended, this is us requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

 

Name of Cookie

Purpose

Expiration

cc_cookie_accept

Stores whether the user has accepted the cookie message or not

365 days

ASP.NET_SessionId

Used for authenticating a user's session after logging in. Closes when you exit the browser.

End of session

ARRAffinity

Tells our infrastructure which server to handle the request.

End of session

MemberLoggedIn

A binary flag which stores whether a user is logged in or not.

End of session

ai_session and ai_user

Tracks users as they navigate the website predominately for infrastructure performance insights.

1 day

DisplayName

Keeps track of a donors preference to show their name during a Direct Debit.

End of session

 

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.

 

The analytics service(s) used by Our Site uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

 

The analytics services used by Our Site use the following Cookies:

 

Name of Cookie

Used By

Description

Expiration

__utma

Google Analytics

Stores the amount of visits of a user, the time of their first visit, the previous visit, and the current visit. It does not contain any personal information and is used only for analytical purposes.  

2 years from set/update

__utmz

Google Analytics

This performance cookie stores where a user came from (e.g. search engine, search keyword, link).

6 months from set/update

_ga and _gid

Google Analytics

Used to distinguish between website users in Google Analytics.

2 years and 2 hours

_gat_UA-XXXXXXXX-X (where the Xs are replaced by the Google Analytics ID number)

Google Analytics

Used to moderate calls to the Google Analytics service.

1 minute

__unam

ShareThis

Set as part of the ShareThis service and monitors "click-stream" activity, e.g. web pages viewed, navigation from page to page, time spent on each page etc. The ShareThis service only identifies a user if they have separately signed up with ShareThis for a ShareThis account and given them consent. Checks how long you stay on a site: when a visit starts, and ends. It does not contain any personal information and is used only for analytical purposes.

14 months

IDE,  DSID,

_ct_rmm

Doubleclick.net

These cookies are managed by DoubleClick, an advertising platform we use to display adverts. They help us identify which visitors to our website have seen or clicked one of our adverts.

2 years from set/update

__cfduid

CloudFlare

Identify individual clients behind a shared IP address and apply security settings on a per-client basis

365 days

 

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

16. How Do I Contact You?

 

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

 

For the attention of:       Ben Hilton

Email address:               [email protected]

Telephone number:        020 3167 1874

Postal Address:              South Vaults, Green Park Station, 2-3 Westmoreland Station Road, Bath, BA1 1IB

 

17. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.