All Aboard Shops – Privacy Policy
All Aboard Shops Limited (“All Aboard”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and/or one of our shops and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
This Privacy Policy is kept under regular review and may be updated from time to time so you may wish to check it each time you submit personal information to All Aboard.
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.
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how All Aboard collects and processes your personal data through your use of this website and/or visit to one of our shops, including any data you may provide when you sign up to our newsletter, volunteer, purchase a product or service, take part in a competition or participate in market research.
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 policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
Controller
All Aboard is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
Third-party links
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 policy of every website you visit.
WHAT INFORMATION ALL ABOARD MAY COLLECT ABOUT YOU
We only collect personal data relevant to the type of transactions or interaction you have with All Aboard.
Whatever your interaction with us this information will be minimal and linked to the purpose for which we need it.
Depending on the type of communication or transaction, we may collect, use, transfer, store and process the following personal data which we have grouped together as follows:
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.
Sensitive Personal Data
Save for as set out below 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.
We only collect "sensitive personal data" about our customers, e.g. health status, where there is a clear and specific reason for doing so and an exemption applies permitting us to do so under applicable data protection laws. If you are part of our team in either a paid or voluntary role, we collect this data where we need it to ensure that we provide appropriate facilities or support to enable you to participate in the event or carry out your role. Clear notices will be provided on application forms so that it is clear what information we need and why we need it. In certain circumstances, such as when we recruit volunteers, we need to obtain information about criminal convictions (where these are unspent) in order to check that it is appropriate for you to undertake the role.
If you apply for a role with us, we may collect this data for equality monitoring. In the event you are applying for a role, a separate privacy policy will be provided to you.
Rarely, we may collect this data for the prevention of crime or dishonesty, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this, we will do it carefully and in accordance with applicable laws.
Should you support All Aboard in a substantial way, we may provide an account manager to help you tailor your relationship to suit your interests. If this is the case, we may collect sensitive personal data where relevant to our relationship, such as your political or religious views. Should you disclose information to us about your health or your family, this may also be recorded, so that we can communicate with you in a considerate and appropriate manner.
All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.
We do not knowingly collect information from / on children
We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to provide us with their personal information without verifiable parent or guardian consent. If you are under 18, do not send any information about yourself to us, including your name, address, telephone numbers, or email address, unless you have your parent's or guardian's permission. In the event we learn that we collected personal information from anyone under the age of 18, and do not have a parent or guardian's consent, we will delete that information as quickly as possible.
If you believe that we might have any information from or about anyone under the age of 18, or if you wish to remove or request and obtain removal of content and information, please contact us at [email protected]
WHEN WE COLLECT INFORMATION ABOUT YOU:
All Aboard may collect your personal data in the following circumstances:
When you give it to us:
You may give us your personal data directly when you make a donation, sign up for one of our events, take part in a campaigning action, request marketing to be sent to you, volunteer at one of our shops or when you purchase products from All Aboard Shops or our eBay site. If you participate in market research, we may ask you questions regarding your shopping with us, or other survey questions relating to your experience.
When you access All Aboard's Social Media:
We might also obtain your personal data through your use of social media such as Facebook, Instagram, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
When we use cookies:
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns and collect this data by using cookies and other similar technologies. Cookies are a useful way for us to understand how supporters use our website and/or use an All Aboard. When you visit our website we will collect data from your computer or other device such as a smart phone or tablet through the use of "cookies". Cookies are created by your web browser when you visit our website. Every time you go back to the All Aboard website, your browser will send the cookie file back to the website's server. They improve your experience of using our website, for example, by remembering your preference settings so that you are presented with information likely to be most relevant to you, and by measuring your use of the website to enable us to continuously improve our website to ensure that it meets your needs. Cookies can also be used to show you relevant All Aboard content on social media services such as Facebook - these are known as "retargeting'" or "advertising" cookies.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), All Aboard may still collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device).
CCTV images:
If you visit one of our shops or sites we may capture you on CCTV. We may also give information to our staff via a feedback process or through our Gift-Aid Scheme. If you participate in an event we may (with your permission) take your photograph or video, or interview you.
Where we consider that, on balance, it is appropriate for us to do so, we will process CCTV footage for legitimate interests. This may include sharing footage with the police or other law enforcement agencies, or our insurers where necessary in relation to a claim, as well as any other third parties in connection with legal proceedings or emergency situations.
WHY WE HOLD AND PROCESS 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:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new donor, fundraiser, customer or volunteer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey or undertake market research
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a competition, complete a survey, undertake market research or participate in a campaign/fundraising event
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our charity and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our charity and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services or campaigns that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our charity)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will do this through a clear statement of what you will receive and allow you to select only those channels that you wish to hear from us by.
All Aboard may contact you in regard to events/ updates etc. We will only contact you for marketing purposes - for example keep you up to date on our work, or let you know of ways in which you can support that work - where we have your consent or we are otherwise allowed to do so.
All Aboard will follow all legal obligations pertaining to the retention and processing of your data. You can update or withdraw your consent at any time, for individual channels of communication, or for all channels.
Third-party marketing
All Aboard will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. 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 experience or other transactions. After opting out, please allow up to seven days for your data to be removed from our systems.
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.
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.
WILL ALL ABOARD SHARE YOUR INFORMATION WITH ANYONE ELSE?
We may share your data with the parties below for the purposes set out in the table above.
All Aboard's suppliers:
We may need to share your information with service providers who help us to deliver our projects, fundraising activities and appeals, for instance through handling responses to our emergency appeals. These "data processors" will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
Facebook and other social media sites:
We may also use your email address and phone number to match to your account on Facebook or other social media sites in order to show you All Aboard content while using these services. We only do this where you have opted in to marketing emails or phone calls and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.
To opt out of social media contact, you can either update your preferences at All Aboard by opting out of the relevant channel of communication, or you can do this via the actual social media websites.
INTERNATIONAL TRANSFERS
We do not transfer your personal data outside of the UK.
HOW ALL ABOARD KEEP YOUR DATA SAFE:
We have put in place appropriate security measures to prevent your personal data from being lost, used, changed or accessed in an unauthorised way. In addition, we limit access to your personal data to all employees and suppliers and other third parties who have a business need to know. They will only process your personal data on All Aboard’s instructions and are subject to a duty of confidentiality.
We ensure that there are appropriate technical controls in place to protect your personal details. For example, information is always encrypted and our network is protected and routinely monitored.
We have also 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 ALL ABOARD KEEP YOUR PERSONAL INFORMATION:
We will hold your personal information on our systems for as long as is necessary for the relevant activity and to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. For example we will keep a record of donations subject to Gift Aid for at least seven years to comply with HMRC rules. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data can be requested from us.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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 RIGHTS OVER YOUR PERSONAL DATA
You have a variety of rights in respect of your data. In particular you may have the right to:
Subject Access Requests
You have the right to request a copy of the personal information we hold about you. We will provide this as soon as possible, and usually within a month unless there are specific reasons why this would not be possible. We will always let you know if this is likely to be the case.
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 could 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 could 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.
Right to be Forgotten
Upon request we will delete your personal data from our systems, to the extent that we are permitted to by law or regulatory guidelines. For instance, under HMRC rules we are required to retain financial data for 7 years for audit purposes, and so will not be able to delete donation details until this time period has elapsed.
HOW TO REQUEST FURTHER INFORMATION OR TO MAKE A COMPLAINT ABOUT ALL ABOARD’S APPROACH TO DATA PROTECTION:
If you would like more information, to update your details or have any questions about this policy, please contact our Data Protection Officer on: [email protected]
In order to track and handle your request, All Aboard can only process and respond to queries, questions or complaints when the following information is shared with your request:
To make a formal complaint about All Aboard’s approach to data protection or raise privacy concerns directly with our data protection team, please contact:
The Data Protection Officer
All Aboard Shops
Stella Lucas House
Unit 10 Colne Way Court
Colne Way
Watford
WD24 7NE
Email: [email protected]
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.
GLOSSARY
Lawful Basis
Legitimate Interest means the interest of our charity in conducting and managing our charity to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Parties
In order to deliver our charitable objectives, All Aboard work with some third party service providers based in the United Kingdom, including:
Your Legal Rights
You have the right to:
All Aboard Shops Limited (“All Aboard”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and/or one of our shops and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
This Privacy Policy is kept under regular review and may be updated from time to time so you may wish to check it each time you submit personal information to All Aboard.
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.
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how All Aboard collects and processes your personal data through your use of this website and/or visit to one of our shops, including any data you may provide when you sign up to our newsletter, volunteer, purchase a product or service, take part in a competition or participate in market research.
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 policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
Controller
All Aboard is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
Third-party links
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 policy of every website you visit.
WHAT INFORMATION ALL ABOARD MAY COLLECT ABOUT YOU
We only collect personal data relevant to the type of transactions or interaction you have with All Aboard.
Whatever your interaction with us this information will be minimal and linked to the purpose for which we need it.
Depending on the type of communication or transaction, we may collect, use, transfer, store and process the following personal data which we have grouped together as follows:
- Identity Data includes first name, last name, title, date of birth and gender.
- Contact Data includes billing address, home address and post code, 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, 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.
- 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.
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.
Sensitive Personal Data
Save for as set out below 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.
We only collect "sensitive personal data" about our customers, e.g. health status, where there is a clear and specific reason for doing so and an exemption applies permitting us to do so under applicable data protection laws. If you are part of our team in either a paid or voluntary role, we collect this data where we need it to ensure that we provide appropriate facilities or support to enable you to participate in the event or carry out your role. Clear notices will be provided on application forms so that it is clear what information we need and why we need it. In certain circumstances, such as when we recruit volunteers, we need to obtain information about criminal convictions (where these are unspent) in order to check that it is appropriate for you to undertake the role.
If you apply for a role with us, we may collect this data for equality monitoring. In the event you are applying for a role, a separate privacy policy will be provided to you.
Rarely, we may collect this data for the prevention of crime or dishonesty, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this, we will do it carefully and in accordance with applicable laws.
Should you support All Aboard in a substantial way, we may provide an account manager to help you tailor your relationship to suit your interests. If this is the case, we may collect sensitive personal data where relevant to our relationship, such as your political or religious views. Should you disclose information to us about your health or your family, this may also be recorded, so that we can communicate with you in a considerate and appropriate manner.
All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.
We do not knowingly collect information from / on children
We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to provide us with their personal information without verifiable parent or guardian consent. If you are under 18, do not send any information about yourself to us, including your name, address, telephone numbers, or email address, unless you have your parent's or guardian's permission. In the event we learn that we collected personal information from anyone under the age of 18, and do not have a parent or guardian's consent, we will delete that information as quickly as possible.
If you believe that we might have any information from or about anyone under the age of 18, or if you wish to remove or request and obtain removal of content and information, please contact us at [email protected]
WHEN WE COLLECT INFORMATION ABOUT YOU:
All Aboard may collect your personal data in the following circumstances:
When you give it to us:
You may give us your personal data directly when you make a donation, sign up for one of our events, take part in a campaigning action, request marketing to be sent to you, volunteer at one of our shops or when you purchase products from All Aboard Shops or our eBay site. If you participate in market research, we may ask you questions regarding your shopping with us, or other survey questions relating to your experience.
When you access All Aboard's Social Media:
We might also obtain your personal data through your use of social media such as Facebook, Instagram, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
When we use cookies:
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns and collect this data by using cookies and other similar technologies. Cookies are a useful way for us to understand how supporters use our website and/or use an All Aboard. When you visit our website we will collect data from your computer or other device such as a smart phone or tablet through the use of "cookies". Cookies are created by your web browser when you visit our website. Every time you go back to the All Aboard website, your browser will send the cookie file back to the website's server. They improve your experience of using our website, for example, by remembering your preference settings so that you are presented with information likely to be most relevant to you, and by measuring your use of the website to enable us to continuously improve our website to ensure that it meets your needs. Cookies can also be used to show you relevant All Aboard content on social media services such as Facebook - these are known as "retargeting'" or "advertising" cookies.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), All Aboard may still collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device).
CCTV images:
If you visit one of our shops or sites we may capture you on CCTV. We may also give information to our staff via a feedback process or through our Gift-Aid Scheme. If you participate in an event we may (with your permission) take your photograph or video, or interview you.
Where we consider that, on balance, it is appropriate for us to do so, we will process CCTV footage for legitimate interests. This may include sharing footage with the police or other law enforcement agencies, or our insurers where necessary in relation to a claim, as well as any other third parties in connection with legal proceedings or emergency situations.
WHY WE HOLD AND PROCESS 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.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new donor, fundraiser, customer or volunteer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey or undertake market research
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a competition, complete a survey, undertake market research or participate in a campaign/fundraising event
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our charity and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our charity and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services or campaigns that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our charity)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will do this through a clear statement of what you will receive and allow you to select only those channels that you wish to hear from us by.
All Aboard may contact you in regard to events/ updates etc. We will only contact you for marketing purposes - for example keep you up to date on our work, or let you know of ways in which you can support that work - where we have your consent or we are otherwise allowed to do so.
All Aboard will follow all legal obligations pertaining to the retention and processing of your data. You can update or withdraw your consent at any time, for individual channels of communication, or for all channels.
Third-party marketing
All Aboard will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. 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 experience or other transactions. After opting out, please allow up to seven days for your data to be removed from our systems.
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.
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.
WILL ALL ABOARD SHARE YOUR INFORMATION WITH ANYONE ELSE?
We may share your data with the parties below for the purposes set out in the table above.
All Aboard's suppliers:
We may need to share your information with service providers who help us to deliver our projects, fundraising activities and appeals, for instance through handling responses to our emergency appeals. These "data processors" will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
Facebook and other social media sites:
We may also use your email address and phone number to match to your account on Facebook or other social media sites in order to show you All Aboard content while using these services. We only do this where you have opted in to marketing emails or phone calls and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.
To opt out of social media contact, you can either update your preferences at All Aboard by opting out of the relevant channel of communication, or you can do this via the actual social media websites.
INTERNATIONAL TRANSFERS
We do not transfer your personal data outside of the UK.
HOW ALL ABOARD KEEP YOUR DATA SAFE:
We have put in place appropriate security measures to prevent your personal data from being lost, used, changed or accessed in an unauthorised way. In addition, we limit access to your personal data to all employees and suppliers and other third parties who have a business need to know. They will only process your personal data on All Aboard’s instructions and are subject to a duty of confidentiality.
We ensure that there are appropriate technical controls in place to protect your personal details. For example, information is always encrypted and our network is protected and routinely monitored.
We have also 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 ALL ABOARD KEEP YOUR PERSONAL INFORMATION:
We will hold your personal information on our systems for as long as is necessary for the relevant activity and to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. For example we will keep a record of donations subject to Gift Aid for at least seven years to comply with HMRC rules. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data can be requested from us.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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 RIGHTS OVER YOUR PERSONAL DATA
You have a variety of rights in respect of your data. In particular you may have the right to:
- 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.
Subject Access Requests
You have the right to request a copy of the personal information we hold about you. We will provide this as soon as possible, and usually within a month unless there are specific reasons why this would not be possible. We will always let you know if this is likely to be the case.
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 could 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 could 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.
Right to be Forgotten
Upon request we will delete your personal data from our systems, to the extent that we are permitted to by law or regulatory guidelines. For instance, under HMRC rules we are required to retain financial data for 7 years for audit purposes, and so will not be able to delete donation details until this time period has elapsed.
HOW TO REQUEST FURTHER INFORMATION OR TO MAKE A COMPLAINT ABOUT ALL ABOARD’S APPROACH TO DATA PROTECTION:
If you would like more information, to update your details or have any questions about this policy, please contact our Data Protection Officer on: [email protected]
In order to track and handle your request, All Aboard can only process and respond to queries, questions or complaints when the following information is shared with your request:
- Contact name
- Contact phone number
- Contact postal address
- Contact email address
To make a formal complaint about All Aboard’s approach to data protection or raise privacy concerns directly with our data protection team, please contact:
The Data Protection Officer
All Aboard Shops
Stella Lucas House
Unit 10 Colne Way Court
Colne Way
Watford
WD24 7NE
Email: [email protected]
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.
GLOSSARY
Lawful Basis
Legitimate Interest means the interest of our charity in conducting and managing our charity to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Parties
In order to deliver our charitable objectives, All Aboard work with some third party service providers based in the United Kingdom, including:
- IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.