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1.1 Citizens Advice West Oxfordshire (CAWO) is committed to protecting the privacy of all staff, volunteers and visitors to http://www.CAWO.org.uk and our social media sites. In this policy we explain how we will handle your personal data.
1.2 CAWO will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.3 This privacy policy was last updated on 01/06/2018
Credit
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
How we use your personal data
3.1 In this Section 3 CAWO have set out:
(a) the general categories of personal data that CAWO may process;
(b) in the case of personal data that CAWO did not obtain directly from you, the source and specific categories of that data];
(c) the purposes for which CAWO may process personal data; and
(d) the legal bases of the processing.
3.2 CAWO may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 CAWO may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.
3.4 CAWO may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
3.5 CAWO may process your personal data that are provided in the course of the use of our services] (“service data”).[ The service data may include your name, address, telephone number, email address. The source of the service data is you. The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you]. The legal basis for this processing is consent.
3.6 CAWO may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
3.7 CAWO may process [information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing services to you. The legal basis for this processing is consent.
3.8 We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website] (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
3.9 CAWO may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.10 CAWO may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 CAWO may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 In addition to the specific purposes for which CAWO may process your personal data set out in Section 3, CAWO may also process any of your personal data, where such processing is necessary for compliance with a legal obligation to which CAWO are subject. Or, in order to protect your vital interests or the vital interests of another natural person.
3.14 Please do not supply any other person’s personal data to us, unless CAWO prompt you to do so.
Providing your personal data to others
4.1 CAWO may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary, for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes, or to the purchaser (or prospective purchaser) of any asset that CAWO are (or are contemplating) selling.
4.2 Financial transactions relating to our website and services are handled by our payment services providers, Go Cardless and Stripe. CAWO will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at:
– Stripe (URL https://stripe.com/gb/privacy)
– GoCardless (URL https://gocardless.com/legal/privacy/)
4.3 Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data CAWO receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:
Your data will be made available to our website provider
The data that may be available to them include any of the data CAWO collect as described in section 3 above.
Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
They will store your data for a maximum of 7 years.
This processing does not affect your rights under sections 10 or 16 of this privacy policy
4.4 In addition to the specific disclosures of personal data set out in this Section 4, CAWO may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which CAWO are subject, or in order to protect your vital interests or the vital interests of another natural person.
International transfers of your personal data
5.1 In this Section 5, CAWO provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 CAWO[ has offices in England only. The European Commission has made an “adequacy decision” with respect to the data protection laws of England.
5.3 The hosting facilities for our website are situated in England. The European Commission has made an “adequacy decision” with respect to the data protection laws of England.
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. CAWO cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that CAWO comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that CAWO process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 CAWO will retain and delete your personal data as follows:
(a) Personal data will be retained for 7 years at the end of which period it will be deleted from our systems.
(b) Notwithstanding the other provisions of this Section 6, CAWO may retain your personal data where such retention is necessary for compliance with a legal obligation to which CAWO are subject, or in order to protect your vital interests or the vital interests of another natural person.
Amendments
7.1 CAWO may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 CAWO may notify you of changes to this policy by email/
Your rights
8.1 You may instruct us to provide you with any personal information CAWO hold about you; provision of such information will be subject to:
the supply of appropriate evidence of your identity [(for this purpose, CAWO will usually
accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a
utility bill showing your current address.
8.2 CAWO may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information for marketing purposes.
8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or CAWO will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
OR
Your rights
8.1 In this Section 8, CAWO have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not CAWO process your personal data and, where CAWO do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, CAWO will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your profile data and adjust your privacy settings by visiting http://www.CAWO.org.uk/my-details when logged into the website.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claim].
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; CAWO no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, CAWO may continue to store your personal data. However, CAWO will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, CAWO will cease to process the personal information unless CAWO can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, CAWO will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 This privacy policy only governs our website and CAWO is not responsible for the privacy policies that govern third party websites even where CAWO have provided links to them. If you use any link on our website CAWO recommend you read the privacy policy of that website before sharing any personal or financial data
9..3 CAWO operate a number of social media pages including Facebook and Twitter. Although this policy covers how CAWO will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.
Personal data of children
10.1 Our website and services are targeted at persons over the age of 16.
10.2 If CAWO have reason to believe that CAWO hold personal data of a person under that age in our databases, CAWO will delete that personal data.
Updating information
11.1 Please let us know if the personal information that CAWO hold about you needs to be corrected or updated.
Acting as a data processor
12.1 In respect of Citizens Advice CAWO do not act as a data controller; instead, CAWO act as a data processor.
12.2 Insofar as CAWO act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that CAWO store about you may be linked to the information stored in and obtained from cookies.
Cookies that CAWO use
14.1 CAWO use cookies for the following purposes (and lists the storage period)
__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 (eg. 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 our Google Analytics ID number).
Google Analytics .Used to moderate calls to the Google Analytics service. 1 minute
__unam Share This. 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
cc_cookie_accept Website. Stores whether the user has accepted the cookie message or not. 365 days
ASP.NET_SessionId Website. Used for authenticating a user’s session after logging in. Closes when you exit the browser.
ARRAffinity Website. Tells our infrastructure which server to handle the request. End of session
MemberLoggedIn Website. A binary flag which stores whether a user is logged in or not. End of session
ai_session and ai_userWebsite. Tracks users as they navigate the website predominately for
infrastructure performance insights. 1 day
DisplayName Website. Keeps track of a donors preference to show their name during a Direct
Cookies used by our service providers
15.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
15.2 CAWO use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. This data may be stored outside the EU, under a EU-US Privacy Shield agreement. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.%5B The relevant cookies are:
_ga, _gid, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv].
Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
Our details
17.1 This website is owned and operated by Citizens Advice North Oxon & South Northants (CAWO).
17.2 CAWO are registered as a charity in England and Wales under registration number 1079719 and our registered office is at 26 Cornhill, Banbury, Oxfordshire OX16 5NG.
17.3 Our principal place of business is at 26 Cornhill, Banbury, Oxfordshire OX16 5NG.
17.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by email to info@citizensadvicenosn.org.uk
Representative within the European Union
18.1 We have no need of representation in the EU.
Data protection officer
19.1 Our data protection officer’s contact details are: Pat Coomber-Wood. Contact details are as those in 17.4
Data protection registration
20.1 CAWO are registered as a data controller with the UK Information Commissioner’s Office.
20.2 Our data protection registration number is Z4709983
Complaints
21.1 If you have a complaint about us, or the treatment of your data, you can contact the Charity Commission. The Charity Commission is the independent watchdog for charities. You can make a complaint about a charity on their website at http://www.charity-commission.gov.uk
21.2 If you’ve got a complaint about our fundraising activities you can also complain to the Fundraising Regulator. To find out how to go about making a complaint, go to the Fundraising Regulator website at https://www.fundraisingregulator.org.uk/make-a-complaint/complaints/