Privacy Notice

Introduction

This privacy notice is for you if you visit our website or use any of our fundraising tools. You might be a:

• Charity customer of our ‘GivePanel’ platform
• Fundraiser for such a charity
• 1-Click user for a fundraiser using our GivePanel 1-Click fundraising tools
• Website visitor

GIVEPANEL LIMITED understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, fundraisers, 1-click users, visitors to our website www.givepanel.com and other stakeholders, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

This Privacy Notice is in several parts. Firstly, the general Privacy Notice includes information for all types of engagement, and then there is additional information for fundraisers.

For individuals covered by the Australian Privacy Principle (APP) 1.3 please see the section at the end of the Privacy Notice.

General Privacy Notice
Fundraisers

Privacy information for individuals covered by the Australian Privacy Principle (APP) 1.3

Privacy Notice – general

1. Who we are and how to contact us

GIVEPANEL LIMITED is a limited company registered in England under company number 04648232, whose registered address is 85 Great Portland Street, London, W1W 7LT.

VAT number: GB127996955

Main trading address: 124 City Road, London, EC1V 2NX

Telephone number: 0203 693 4470

Office email: hello@givepanel.com

Data Protection Officer:

Email address: dpo@givepanel.com

Postal address: 124 City Road, London, EC1V 2NX

EU Representative:

Email address: EURep@givepanel.com

Postal address: c/o GivePanel, 124 City Road, London, EC1V 2NX

We are accredited with Cyber Essentials and you can search for our registration here.

We are subject to the UK GDPR.

If you have a query regarding how we use your personal data or to exercise your rights, please contact our Data Protection Officer using any of the ways mentioned above.

If you are an EU citizen, you can also contact our EU representative using the contact details above.

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

If your enquiry concerns how your personal data is processed by the charity you have agreed to support, we encourage you to contact them in the first instance.

3. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

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

The personal data that we use is set out in Part 6, below.

4. Are we a controller or processor?

We are a Controller for :

• Customer account and usage data
• 1-Click fundraiser account and usage data
• Data processed for the purpose of business administration

We are a Processor for :

• Data that customers upload and maintain (either automatically or manually)

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 1.
• The right to access the personal data we hold about you. Part 11 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 1 to find out more.
• The right to erasure (often called the right to be forgotten), i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 1 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
• You also have the right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 1.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data if we are the controller. Please advise the charity if they are the controller.

Further information about your rights can also be obtained from the Information Commissioner’s Office at ico.org.uk or 0303 123 1113.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 1.

6. What Personal Data Do You Collect and How?

Depending on the ways in which you engage with us, we may collect and hold some or all of the personal data set out below, using the methods set out there.

We do not collect any ‘special category’ (‘sensitive’) personal data. We do not collect data relating to criminal convictions and/or offences.

We do not knowingly process data for children under 18 years of age. If we are advised of any data in the category, we will erase it.

We may collect personal data about you using the following methods:

• Provided by you
• By a direct interaction with you
• Via our website
• Added to the GivePanel platform by a charity that you are fundraising for
• By a third party when you choose that they pass this information to us, for example when you register to attend an event or make a donation
• Publicly available data relating to charities

We may collect the following types of personal data:

• Identity Information including name, title, date of birth, gender.
• Contact information including postal address, email address, telephone number (landline and/or mobile).
• Professional information including qualifications, expertise, areas of interest
• Profile information including preferences, interests, login details, purchase history, website pages you click to, through and from
• Payment information including amounts, dates, requested purposes and whether you self-select as qualifying to donate by Gift Aid, for donations and the purchase of products and services
• Technical information including IP address, browser type version and plugins, operating system, time zone, operating systems and platforms
• Third party data, including identity, contact and profile information, from publicly available sources and data procurement companies

Our website may contain links to other websites that are outside our control and are not covered by this privacy notice. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy notice, which may differ from ours. Please make sure that you check the privacy notices of these sites.

7. How Do You Use My Personal Data?

Under UK data protection legislation, we must always have a lawful basis for using personal data.

The possible lawful bases for processing are set out in Article 6 of the UK GDPR and are:

• Consent: you have given clear consent for us to process your personal data for a specific purpose.
• Contract: the processing is necessary for a contract we have with you, or because you have asked you to take specific steps before entering into a contract.
• Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
• Vital interests: the processing is necessary to protect someone’s life.
• Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

The following table describes how we may use your personal data (our purpose of processing), and our lawful bases for doing so:

With your permission and/or where permitted by law, we may use your personal data for marketing purposes, which may include contacting you by email and post with newsletters, fundraising appeals, campaigns, or other information or with information about ourproducts or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the UK data protection legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We will never share, rent or sell your personal data to third parties for their own marketing purposes.

We do not use automated systems for carrying out decision-making or profiling. However, we may use manual profiling and screening techniques to ensure communications are relevant and timely, and to provide an improved experience for our active and prospective customers.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 1 below.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the data protection legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Notwithstanding the above, system backups are undertaken automatically, and we also take independent offline backups on a 3-tier basis (daily kept for 7 days, weekly kept for 5 weeks and monthly kept for 12 months). Therefore a backup of data may be kept for up to 12 months, but these offline backups are physically secured and not accessible to anyone other than a GivePanel system administrator.

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

We may store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation (UK GDPR and the Data Protection Act 2018).

We may store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to and from the EEA are permitted without additional safeguards.

We may store some of your personal data in countries outside of the UK and the EEA and these are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation by using Standard Contractual Clauses (“SCC’s”).  For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 1 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.

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

We may sometimes contract with the following third parties to supply products or services as follows:

• Hosted database, development platform and tools – Google (US & EEA), Twilio (UK), MongoDB (US & EEA) and HelpScout (US)
• Business services – Xero (New Zealand), MBS Accountants (UK), PayrollSorted (UK), Accountant Online (EU), Systemagic (UK), Whosoff (UK), Wise (UK)
• Marketing – Hubspot (US)
• Analytics – PostHog (US)

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

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

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

11. How Can I Access My Personal Data?

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

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 1.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress. We may require proof of your identity before we can process your request.

12. Changes to this Privacy Notice

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

Any changes will be made available at www.givepanel.com/privacy and you can request a copy in printed form or other accessible format by contacting us using the details in Part 1. This Privacy Notice was last updated on 26th July 2022.

Privacy Notice – additional information
for Fundraisers

What personal data do you collect and how? The GivePanel platform allows charities to upload the data contained in the Facebook multi-day transaction report. In addition, a charity may add custom fields of their own choosing.

How can I access my personal data? You can contact us as described in part 11. However, in the first instance you may wish to contact the charity for whom you are fundraising as they are the controller of any data uploaded or maintained on the GivePanel platform.

Australian Privacy Principle (APP) 1.3

GivePanel AUS has an Australian link as it carries on business in Australia. Therefore APP 1.3 applies to the personal information of individuals physically present in Australia. 

This Privacy Notice fulfils APP 1.3 for a clearly expressed and up to date policy (also known as the APP privacy policy) which contains:

• The kinds of personal information that the entity collects and holds – see section 6 above
• How the entity collects and holds personal information – see section 6 above
• The purposes for which the entity collects, holds, uses and discloses personal information – see section 5
• How an individual may access personal information about the individual that is held by the entity and seek the correction of such information – sections 1, 5 and 11 above
• How an individual may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint – see sections 1 and 5 above
• Whether the entity is likely to disclose personal information to overseas recipients – see section 10 above
• If the entity is likely to disclose personal information to overseas recipients—the countries in which such recipients are likely to be located if it is practicable to specify those countries in the policy – see section 10 above