Last updated: 29/03/2021

Introduction

Cruelty Free International and Cruelty Free Europe are committed to protecting your privacy and we want everyone who supports us, to feel confident about how we protect and use any personal data you provide to us, or that we collect from you.

This privacy policy explains how we process personal data at Cruelty Free International and Cruelty Free Europe.

Cruelty Free International and Cruelty Free Europe act as “joint data controllers”. This means that both parties are responsible for, and control the processing of, any personal information that you either provide them with or that they collect from you.

Cruelty Free International is a company limited by guarantee registered in England and Wales with registration number 04115167 and registered office address 16a Crane Grove, London, N7 8NN. Cruelty Free Europe aisbl, established by Royal Decree on 17 February 2019, registered at the Tribunal de l’entreprise de Bruxelles, Company number BE 721976146, EU Transparency Register No: 842315534764-63. (hereinafter jointly referred to as “the Parties”, “we” or “us”.

Both parties shall comply with Cruelty Free International’s data protection policies including (without limitation) Cruelty Free International’s Data Privacy Policy and Data Retention Policy (and Schedule).

We make every effort to ensure that your personal information is processed in a fair, open and transparent manner, in line with the General Data Protection Regulation (UK), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and the General Data Protection Regulation (GDPR).

Please read this policy carefully, along with any other documents referred to in this policy, to understand how we collect, use and store your personal information.

What is the purpose of this document?

This Policy sets out why we collect personal data about individuals and how we use it. It also explains the legal basis for this and the rights you have regarding the way your personal data is used.

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

1. How we collect information about you

We collect personal information about you in the following ways:

When you interact with us directly: This could include when you enquire about our activities, register for an event with us, make a donation, sign a petition, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This also includes when you phone us, visit our website, or get in touch through the post, or in person.

When you interact with us via third parties: This could be if you provide a donation to us via a third party platform such as JustGiving or one of the other third party providers that we work with when you provide your consent for your personal information to be shared with us.

When you visit the Cruelty Free International or Cruelty Free Europe website: We gather general information which might include which pages are visited most often and which services, events or information which is of most interest to you. We may also track which pages you visit when you click on links in emails from Cruelty Free International or Cruelty Free Europe. We also use cookies to help our site run effectively. Please look at the ‘Cookies’ section below on what this means for you.

We use this information to personalise the way the Cruelty Free International or Cruelty Free Europe website is displayed when you visit and to make improvements to ensure we provide you with the best service and experience possible. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our website.

When your information is available publicly. So that we can tailor the way we communicate with you about our work and make our communications more relevant to you, we might gather publicly available information about you. This could include your interests, postcode-based demographics, and past campaigning or donation activities. Through understanding more about you we can be more cost-effective in our marketing, campaigning and fundraising communications to you, and better inform you about our work.

We may gather this information from online articles and newspapers, and social media platforms such as Facebook, LinkedIn, Twitter or Instagram. This information is only accessible based on the permission you give through these services. If you are unsure about what these permissions are, or would like to change them, check the privacy notices on their websites.

We might also gather publicly available information about individuals who may be interested in supporting or giving major gifts to charities or organisations like us in the future. However, we will never keep potential donors’ publicly available information without their consent, which will be sought at the earliest practical opportunity. 

1. Information we collect and why we use it

Personal Information

The information we collect might include personal details such as your:

• First and Last Name
• Date of birth
• Gender
• Email address
• Postal address
• Telephone number
• Employment history and qualifications (if you apply for a job or volunteering opportunity)
• Credit/debit card details (if you are making a purchase or donation)
• UK tax payer (to confirm Gift Aid if opted in)

as well as additional information you provide in any correspondence between us

N.B.

Credit and debit card payment information

If you use your credit or debit card to make a donation or fundraise for us, we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard (PCI DSS). To find out more about PCI DSS standards, visit their website at www.pcisecuritystandards.org Following the completion of your transaction, card details and validation codes are securely destroyed once the payment or donation has been processed.

We will use this information:

• To keep a record of your relationship with us
• To provide the services or goods you have requested
• To update you with important administrative messages about your donation, an event or services you have requested
• To keep you informed of your job or volunteering application with us
• To process your donations and/or other payments, to claim gift aid on your donations and verify any financial transactions
• For marketing, fundraising, campaigning and membership services
• For monitoring, evaluation and audit of service provision
• To invite you to participate in surveys or research

For us to undertake the above we need to collect personal data from you for either correspondence purposes or detailed service provision, depending on the service you are accessing,

Our aim is not to be intrusive and we undertake to not ask for irrelevant or unnecessary information.

We may pass your personal data on to other service providers who are contracted to us in the course of dealing with you or your information may be collected by other service providers on our behalf for example when collecting payment for a donation or service. Our contractors are obliged to store your details securely and use them only to fulfil the service they provide for you on our behalf. If you would like further information on this, please do not hesitate to get in touch with us. Once your service need has been satisfied your details will be disposed of securely in line with our procedures set out in our data retention policy. Please contact us for further information regarding this.

Your communications with our teams (including by telephone or email) may also be monitored and/or recorded for training, quality control and compliance purposes.

Sensitive personal information as defined under article 9 of GDPR

Sensitive personal data as defined under article 9 of GDPR covers the following data types:

• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• physical or mental health conditions
• genetic data
• biometric data
• sexual life and sexual orientation
• the commission or alleged commission of any offence; or
• any proceedings for any offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings

We will not pass on your details without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others, children contacting us and sharing serious issues.

If you provide us with any Sensitive Personal Data by telephone, email or by other means, we will treat that information with extra care and always in accordance with this privacy policy.

We will only use sensitive information about you such as, your disability status to consider whether we need to provide appropriate adjustments during our recruitment process if you have applied for a job or volunteer opportunity with us.

If you provide us with information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. We will only process information regarding criminal convictions if we need to in line with our recruitment process.

Your personal information and details of the enquiries received are stored on a secure database for no longer than is necessary for the purposes of its use. We carry out periodic deletion of data whose retention period has expired and/or when the need to continue holding such data is no longer necessary.

1. How we use your personal information

Give important information and support you’ve asked for, whether this be over the phone, via text message, social media or through an email or post.

Provide or administer activities relating to all our services: updating you with important administrative messages, to help us identify you when you contact us, and help us to properly maintain our records.

We may use your information to enhance the service that our staff provide, to improve our information and communications, or to personalise the website to better suit your needs.

Provide you with information about our plans. This may be letting you know about new services that we hope will be useful and interesting to you, and may include fundraising updates; of course, we will only do this either with your consent, where we need to fulfil a contract or service with you, or where we believe you will expect to be updated and contacted by us

Analyse the personal information we collect about you so that we can better understand our supporters, their preferences and needs and important trends.  This may mean looking at all the interactions you have with us so we can aim to offer you the right information or offers at the right time; including financial interactions so we can ensure we ask you for an appropriate level of support. It may also mean collecting information about you from publicly available sources or through third-party subscription services or service providers; information may include details about the area where you live, or people like you, so we can better inform how we talk to you about our work. We believe this enables us to offer you more appropriate offers and communications, you can of course opt out of this activity at any time by enforcing your right to object to profiling based activities by contacting us.

We may need to disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements;

To do some of this, we may share your information with our trusted partners and suppliers, but is always carried out under our instruction, and is never for their marketing approaches. We ensure that they store the data securely and delete it when it is no longer needed.

1. Legal basis for your information

Where consent is the appropriate legal basis for using your personal information, we will use this only once we have your consent for the specific service or request, we are fulfilling for you.

The are other lawful reasons that allow us to process your personal information and one of these is referred to as ‘legitimate interests’. This means that the reason we are processing your information is because there is a legitimate interest for us to do so. Examples of where we have legitimate interest includes, contacting you about our work via post, using your personal information for data analytics, conducting research to better understand our supporter base, improving our services and communications or for our legal purposes, such as dealing with complaints and claims. We will make it easy for you to opt-out of postal communications and fundraising activities at any time if you wish.

Whenever we process your personal information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and we will not process your personal information if we feel there is not a legitimate reason for us to do so.

In cases where we may need to transfer and process your personal information outside the EEA, we will comply fully with our legal obligations as a data controller and take all steps necessary to ensure that your personal information is treated securely and in accordance with legislation.

1. Marketing

We’d like to keep you in the loop regarding our progress as an organisation. So, to update you on what we’re doing and ask whether you’d be able to support us, where we are able to, we’d like to keep in touch with you (by post, phone, email, text and other electronic means) about our progress and how you can continue to help us in this important mission.

We will only contact you about Cruelty Free International or Cruelty Free Europe’s work and how you can support either Cruelty Free International or Cruelty Free Europe by email or text message if you have opted-in to receive communications from Cruelty Free International or Cruelty Free Europe respectively via these channels.

However, if you have provided us with your postal address or phone number we may send you information about Cruelty Free International or Cruelty Free Europe’s work and how you can support Cruelty Free International or Cruelty Free Europe by mail or phone unless you have specifically told us that you would prefer not to hear from us in this way.

You can update your preferences with us by contacting us or by clicking the unsubscribe button at the bottom of relevant communications.

1. Who sees your personal information?

The personal information we collect about you will be used by our staff (and volunteers) at Cruelty Free International and Cruelty Free Europe so that they can support you; also, by selected organisations that work with us or on our behalf to deliver our services; and possibly to legal and regulatory authorities if required to by law.

We will never sell or share your personal information with organisations except where there is a service need to do so. Where this is the case you will have agreed to this as part of the service being offered (e.g. when donating via a third-party supplier). You have the right to prevent this, however it may affect the level of service we can provide you. We never sell or share your information so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity

We may need to disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements;

To do some of this, we may share your information with our trusted partners and suppliers, who work with us on our behalf to deliver our services. In the contracts with our service providers we require that the processing of your personal information is always carried out under our instruction and is never for their marketing approaches. We ensure that they store the data securely and delete it when it is no longer needed.

Some examples of where we may share your information are with our fulfilment partners who help to create and send information to you to reduce our costs, or with our partners who help us to process donations and claim Gift Aid.

We may also use information to produce anonymous reports to our funders and stakeholders.

1. Keeping your information safe

We will take all reasonable care to safeguard your information, through security policies and secure business processes and we take the security of your personal information very seriously.

We've implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.

And, we only keep it as long as is reasonable and necessary, which may be to fulfil statutory obligations.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information only to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained on request.

Details relating to any transactions entered into through the Cruelty Free International or Cruelty Free Europe websites will be encrypted in transit to ensure their safety. Encryption is the process through which sensitive information is scrambled before it is transmitted so that it remains private even if it is intercepted. However, unless your internet browser supports you will not be able to take advantage of this level of security.

Offline, your personal information is kept in our databases and offices, or, where relevant, by our partner companies.

Any debit or credit card details which we receive on our website are passed securely to our payment processing partner, according to the Payment Card Industry Security Standards.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

1. Third party links

The Cruelty Free International and Cruelty Free Europe websites may contain links to third-party websites. These websites should have their own privacy policies and as such we do not accept any responsibility or liability for their policies.

Please be aware that advertisers or Web sites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites or advertisers.

1. How long we hold your information

We will endeavour not to keep your personal information for longer than necessary and to keep your information accurate and up to date for the period that we retain it. Once you no longer need our services, we are legally required to keep records for a period of time depending on the type of data we hold. After this time, we will securely destroy it according to our data retention policy. Please get in touch with us for further information on our data retention periods.

1. Your rights

Please be reassured that respect lies at the heart of everything our committed staff and volunteers do. However, you have a variety of rights in respect to the personal information that we hold about you which are set out below. If you wish to exercise any of these rights or make a complaint, please get in touch with us directly.

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no lawful reason to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). –
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
• Object to automated decision making. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law.

Please note that some of these rights only apply in certain circumstances and we may not be able to fulfil every request. We may also ask you to verify your identity so that we can evidence it is in fact you are making the request.

1. How to update or access your personal information

You have the right to know what personal information we hold about you and how we process it. To request a copy of your personal information, update your details with us, correct or remove information you think is inaccurate or find out more about our privacy and data retention practices, please contact us by:

Writing: Cruelty Free International, 16a Crane Grove, London, N7 8NN

Email: info@crueltyfreeinternational.org

Tel: 0207 700 4888

Responsibility for data protection compliance at Cruelty Free International and Cruelty Free Europe

The Deputy Chief Executive at Cruelty Free International is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Deputy Chief Executive.

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. You can do that here https://ico.org.uk/

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A cookie in no way gives us access to your computer or any information about you, other than the data you have chosen to share with us.

We sometimes use traffic log cookies to identify which pages are being used on our website. This helps us analyse data about web page traffic and improve our website in order to tailor it to user needs. We only use this information for statistical analysis purposes.

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