This is STV Appeal’s Privacy Notice. STV Appeal is a Scottish Charitable Incorporated Organisation (registered charity number SC042429) with its principal office at Pacific Quay, Glasgow, G51 1PQ. STV Appeal is the data controller and is responsible for looking after your personal data in line with data protection and privacy laws.
We are committed to ensuring your privacy and protecting the data we hold about you. This Privacy Notice explains how we do this, and describes how and when STV Appeal collects and processes your personal data.
Please note that we update our Privacy Notice from time to time, so please take a fresh read through every so often. If we make significant changes, we will make that clear on our micro site, or by some other means of contact such as email.
This Privacy Notice was last updated on 22 May 2018.
1. WHAT DATA IS COLLECTED AND WHEN?
The type of information that will be collected will vary depending on the means by which we collect it and includes:
Contact Data: Any personal data you provide to us if you get in touch with us via email, phone or post with any comments or questions; data we collect about you in a business capacity, or otherwise from a business website; and data that is otherwise publicly available. This personal data could include name, address, email address, telephone number and job title.
Data from Other Sources: We receive personal data from other sources, such as:
- our Fundraising Partners who operate Fundraising Platforms like JustGiving, BT My Donate, Virgin Money Giving and Kiltwalk when you open a fundraising page on any of their websites or, when you make a donation in aid of STV Appeal
- our Event Partners like Kiltwalk, the Great Run Company and Pedal for Scotland when you agree to participate in an event organised by our Event Partners, and fundraise in aid of STV Appeal.
Please note that the Donate Now button on our micro site, when clicked,
takes you off of our micro site and to the JustGiving fundraising
platform. Your activity there, including any donation you make to us,
is governed by JustGiving's
Marketing Data: Includes your contact details.
Photo/Video Data: Any photos or video that you provide to us or, where you agree, a third party (whether a charitable organisation, or television broadcaster or producer) provides to us, for publication on our micro site and social media, or any other of our marketing means.
You can ask us to amend your details by e-mailing us directly at email@example.com. We will then process your request as soon as possible.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
STV's Website & Cookies
STV Appeal's micro-site is hosted on STV Central Limited's (Company Number SC172149) ("STV") website at www.stv.tv.
Although STV Appeal works closely with STV and it provides processing and support services to us (including the hosting of this micro site on its website at www.stv.tv), for the purposes of charity, data protection and privacy laws STV Appeal is independent of STV.
The only cookies operative on our micro site are Adobe analytical cookies and these are used for statistical analysis of the use of our micro site. None of that is personalised to users. STV Appeal does not collect information identifying its micro site users. By using our micro site without changing your browser settings we'll assume you’re ok with this
3. HOW AND WHY WE COLLECT DATA
We do not collect personal data through our micro-site.
Data protection and privacy laws permit us to collect and use your personal data on a limited number of grounds. The key grounds upon which we rely are one or more of the following:
- Where we need it to fulfil the contract we have with you
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (please see below for more info)
What do we mean by“Legitimate
Interests”? In certain situations, we collect and use your
personal data to pursue our legitimate interests in a way which might
reasonably be expected as part of running our charity successfully and
efficiently, and which does not materially impact your rights, freedoms
- Where we have your consent
The only circumstance in which we rely on consent as our basis for
processing your personal data relates to your preferences in receiving
marketing from STV Appeal if you are an individual, and not a business
- In order to comply with a legal or regulatory obligation.
In the table below we have set out a summary of when we process your
personal data and our legal bases for doing so. Note that we may
rely on more than one basis:
|Purpose/Activity||Type of data used||Basis for processing|
|To send you promotional material you have requested in relation to a fundraising event you are organising||Contact Data||Legitimate interests - to promote fundraising initiatives|
|To manage our relationship with
you which will include:
||Contact Data|| Legitimate interests:
|To contact you to establish new corporate relationships||Contact Data||Legitimate interests:
|To promote us, our services and
initiatives including fundraising and
other initiatives undertaken by us or our supporters
|To process, administer and
analyse donations made to us to improve our
supporter and fundraising relationships and our marketing
||Data from Other Sources
|Sharing of data with data
processing companies who act on our behalf
Data from Other Sources
|To provide analysis of
fundraising and donations and to process applications re Gift Aid to
the tax authorities
||Data from other Sources
4. SHARING OF PERSONAL DATA
We share your data in the following circumstances:
- When we engage data processing companies, like STV, to act on our behalf from time to time to help manage your data, to provide analysis and to deliver specific functionality. STV may engage sub-processors for some purposes, like IBM which maintains STV’s database.
- Where STV produces programmes about issues that STV Appeal is concerned with, and looks to source contributors to those programmes, we will share case studies with STV for it to consider including them in programmes. STV will enter into a separate agreement with you if it is agreed you will contribute to a programme.
- Where we are required or permitted to do so by law, or to protect or enforce our rights or the rights of any third party or our users.
- Where you agree.
We do not share personal data with Optical Express but we do
engage them, from time to time, to enable donations to be made to us by
phone. They will collect data from you on our behalf and process
We require all of these organisations to respect the security of your personal data and to treat it in accordance with the law and our strict instructions. We do not allow such third parties to further use or share your personal data. We also require them to have appropriate technical and operational security measures in place.
Transfers of Data Out of the EEA: STV Appeal does not transfer personal data outwith the EEA.
We will only send you marketing emails where you have given consent for us to do so, except where you are a business to business contact where sending you marketing emails is within our legitimate interests to raise awareness of STV Appeal, promote our initiatives and to seek corporate engagement and funding.
Some of these communications are issued regularly (as is the case with regular event emails like those we send regarding Pedal for Scotland, for example); others will be prompted by specific events, campaigns or initiatives. Please note that these communications may be selected for you on the basis of Contact Data or Data from Other Sources.
You can unsubscribe to any marketing email via the unsubscribe option at the foot of any marketing email, or contact us at firstname.lastname@example.org.
We do not sell your personal data to any other organisation. We do not pass your personal data to any other organisation for any other purpose than as set out in this Privacy Notice.
6. STV CENTRAL LIMITED (STV)
As we have explained above, STV hosts our micro-site on its Services. Although we work closely with the STV, and we appoint it as a processor of personal data on our behalf, it is an independent body from STV Appeal. The personal data it processes on our behalf is kept separate from any other personal data collected by STV. STV Appeal is the relevant data controller of your personal data and it is processed in accordance with this Privacy Notice.
7. LINKS TO OTHER SITES
To inform and enhance your experience when on our micro site, we provide a number of links to other organisations’ websites who apply their own privacy policies. Please note that this Privacy Notice will not apply to any such website. We do not control, or have any responsibility for, them.
8. YOUR RIGHTS
You have the right to:
- Request access to a copy of the personal data we hold about you (commonly known as a“data subject access request”).
- Request correction of any inaccurate personal data that we hold about you.
- 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. 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. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Withdraw consent to our sending you marketing emails.
- 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.
- If you wish to exercise any of the rights set out above, please contact us. Contact details can be found below.
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.
9. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will retain your email address for as long as you agree or have not objected to receiving emails from us. We will retain other contact details for as long as you are happy to receive communications from us. We will maintain financial records for a period of 7 years. We will review with you annually whether we should continue to retain photos or video you have provided to us.
In some circumstances we may 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.
10. CONTACT DETAILS
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Data Governance Manager at STV Appeal, Pacific Quay, Glasgow G51 1PQ or by email at email@example.com.
Updated: 22 May 2018