Privacy Policy

Privacy Policy

Privacy Policy – The Baily Thomas Charitable Fund

  1. OUR APPROACH

    1. The Baily Thomas Charitable Fund (Registered Charity Number: 262334): (“we” and “us”) is committed to protecting your privacy. This Privacy Policy (the “Policy”) explains (i) how we process the personal information we collect about you, (ii) how you can instruct us if you prefer to limit the use of that information and (iii) what procedures we have in place to safeguard your privacy.
    2. This Policy should be read in conjunction with the Terms and Conditions of use for the Website of which it forms part (the “Terms”).
    3. If you do not agree with this Policy, you must not use this Website or submit information to us through or in connection with this Website.
    4. If you have any questions about this Policy, please write to The Baily Thomas Charitable Fund, c/o TMF Global Services (UK) Limited, 13th Floor, One Angel Court, London, EC2R 7HJ or email us at info@bailythomas.org.uk
  2. WHAT IS PERSONAL DATA?

    • Personal data means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, credit / debit card number, IP address and location data (“Personal Data”).  
  3. THE INFORMATION WE COLLECT AND HOW WE USE IT

    1. We will use, store or otherwise process any of your Personal Data in accordance with the terms of this Policy, including but not limited to, your name, postal address, e-mail address, telephone number, bank details and any other Personal Data collected on registration, on making an application, following a successful grant application and through surveys to the extent reasonably necessary to provide the offerings that are available through our Website to you by us.
    2. We will only process your Personal Data, in accordance with applicable law, for the following purposes:
      1. dealing with your enquiries and requests;
      2. creating and maintaining your profile;
      3. administering application records and assessing applications for grants;
      4. providing grants and personalising your interaction with us;
      5. reimbursing any expenses in relation to issued grants;
      6. enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions;
      7. ensuring the security of your account and our organisation, preventing or detecting fraud or abuses of our Website;
      8. resolving any disputes, if you lawfully exercise your rights or if you wish to dispute the outcome of a grant application, for example, or any other part of our offering;
      9. carrying out fundraising and market research campaigns and sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our offering, which we consider may be of interest to you;
      10. developing and improving our offering, for example, by reviewing visits to our Website and its various subpages and demand for specific grants; and
      11. to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
    3. We will take reasonable steps to ensure the Personal Data that we store is accurate, complete and up-to-date.
  4. GROUNDS FOR PROCESSING

    1. To process your Personal Data lawfully we need to rely on one or more valid legal grounds. The grounds we may rely upon include:
      1. your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes; 
      2. our legitimate interests as a charity (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your Personal Data to prevent or detect fraud or abuses of our Website;
      3. our compliance with a legal obligation to which The Baily Thomas Charitable Fund is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your Personal Data as part of such investigation; or
      4. if you are a grant applicant, because processing your Personal Data is necessary for the performance of a contract.
  5. INFORMATION FOR MARKETING PURPOSES

    1. Where you have consented to us using your Personal Data for marketing purposes, we may use your information to conduct marketing and data analysis or to send you information about our Website, updates and news concerning The Baily Thomas Charitable Fund and its business partners and information about our offering or offerings jointly provided with or on behalf of other organisations.  Alternatively, you may ask us to provide you with such information by sending us an e-mail at info@bailythomas.org.uk or writing to us at the following address: The Baily Thomas Charitable Fund, c/o TMF Global Services (UK) Limited, 13th Floor, One Angel Court, London, EC2R 7HJ.
    2. If you stop using the Website or your permission to use the Website is terminated, we may continue to use and disclose your Personal Data in accordance with this Policy (as amended from time to time) and as permitted by law.  However, if at any time after you have consented to us using your Personal Data for marketing purposes and you wish us to stop using your information for these purposes, please contact us in writing or via email at the relevant address in clause 5.1.
  6. INFORMATION SECURITY

    1. The Internet is not a secure medium. However, we have put in place various security procedures as set out in this Policy.
    2. Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
    3. We believe that we have appropriate policies, rules and technical measures to protect the Personal Data that we have under our control (having regard to the type and amount of that Personal Data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
  7. DISCLOSURE OF YOUR PERSONAL INFORMATION

    1. There are circumstances where we may wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
      1. to our employees;
      2. to our trustees;
      3. to our affiliates (if any);
      4. to our successors in title to our activities;
      5. to our auditors;
      6. to our outsourced service providers or suppliers who assist us in operating our Website and running the charity (including but not limited to IT support service providers), so long as those parties agree to keep the Personal Data confidential;
      7. subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means;
      8. to third party service providers and consultants in order to protect the security or integrity of our organisation, including our databases and systems and for business continuity reasons;
      9. to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor;
      10. to legal advisors who may need to manage or litigate a claim;
      11. to public authorities or other third parties where we are required by law to do so; and
      12. to any other third party where you have provided your consent.
  8. INTERNATIONAL TRANSFER OF PERSONAL DATA

    1. We may transfer your Personal Data to a third party in countries outside the EU for further processing in accordance with the purposes set out in this Policy. In particular, your Personal Data may be transferred to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. 
    2. We may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting The Baily Thomas Charitable Fund.
  9. RETENTION OF PERSONAL DATA

    1. Your Personal Data will be retained for as long as it is necessary to carry out the purposes set out in this Policy (unless longer retention is required by the applicable law). However, we will not retain any of your Personal Data beyond this period and the retention of your Personal Data will be subject to periodic review. We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
  10. YOUR RIGHTS IN RELATION TO YOUR INFORMATION

    1. Data protection law provides you with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, your Personal Data.  You also have the right to lodge a complaint with the relevant data protection authority if you believe your Personal Data is not being processed in accordance with applicable data protection law.
    2. Right to make subject access request (SAR).  You may, where permitted by applicable law, request copies of your Personal Data.  If you would like to make a SAR, i.e. a request for copies of the Personal Data we hold about you, you may do so by writing to Ann Cooper, Secretary to the Trustees at The Baily Thomas Charitable Fund, c/o TMF Global Services (UK) Limited, 13th Floor, One Angel Court, London, EC2R 7HJ or emailing us at info@bailythomas.org.uk.  The request should make clear that a SAR is being made.  Please quote your name and address. We should be grateful if you would also provide brief details of the information of which you would like a copy or which you would like to be corrected (see clause 10.3 below) - this helps us to more readily locate your data. We will require proof of your identity before providing you with details of any Personal Data we may hold about you.
    3. Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete Personal Data. 
    4. Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your Personal Data is essential.
    5. Right to object to processing. You may, as permitted by applicable law, request that we stop processing your Personal Data
    6. Right to erasure. You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so.
    7. Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.
  11. COOKIE STATEMENT

    1. What exactly are cookies?
      In order to collect the information as described in this Policy, we use cookies on our Website.
    2. A cookie is a small file that a website or its service provider transfers to your computer’s hard drive, mobile phone or other device, through your web browser (if you agree) that enables the websites or service providers systems to recognize your browser and capture and remember certain information.
    3. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.  Alternatively, you can choose to turn off all cookies via your browser settings. However, some of the services and features offered through our Website may not function properly if your cookies are disabled.
    4. Cookies can be first party or third party cookies.
      • First party cookies - cookies that the website you are visiting places on your computer.
      • Third party cookies - cookies placed on your computer through the website but by third parties, such as, Google.
    5. What cookies are used on our Website?
      ​We use the following cookies on our Website:
      1. ​​Strictly necessary cookies
        These cookies are essential in order to enable you to move around our Website and use its features, such as accessing secure areas of the Website. Without these cookies, services you have asked for cannot be provided.  These cookies are first party cookies. They are deleted when you close the browser.
      2. Performance cookies
        These cookies collect information in an anonymous form about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it as well as the approximate regions that they are visiting from. These are first party cookies.
      3. Functionality cookies
        These cookies allow the Website to remember choices you make (for example, choice of language or region) and provide enhanced, more personal features when you return to our Website. These are first party cookies.
    6. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our Website. For more information please visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.
    7. More information about cookies used on Website
      You can find more information about the individual cookies used on our Website and the purposes for which we use them in the table below:
      Cookies used on Website 

      Cookie name

      First or third party

      Purpose

      Expiry

      Session

      First

      [Performance/ Functionality]

      At end of browser session

      cookie-agreed-version

      First

      [Stores user consent]

      100 days

      _ga

      Third

      (Google Analytics)

       

      [Website analytics]

      Two years

      _gid

      Third
      (Google Analytics)

      [Website analytics]

      24 hours

      _gat

      Third

      (Google Analytics)

       

      [Website analytics]

      Immediately

  12. LINKED WEBSITES

    • We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our Website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.
  13. THIRD PARTIES

    • Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their Personal Data, the reason you have provided it, how they can contact us, the terms of this Policy and that they have consented to such collection, use and disclosure.
  14. FURTHER INFORMATION

    • For further information from us with regard to this Policy, please write to The Baily Thomas Charitable Fund, c/o TMF Global Services (UK) Limited, 13th Floor, One Angel Court, London, EC2R 7HJ or email us at info@bailythomas.org.uk.
  15. COMPLIANCE WITH PRIVACY LAWS

    • The Baily Thomas Charitable Fund complies with the data protection and privacy laws to which it is subject.  You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them.  You should also be aware that privacy laws in various jurisdictions may change from time to time. 
  16. CHANGES TO THIS POLICY

    • We reserve the right to amend or modify this Policy without notice to you and if we do so we will post the changes on this page. It is your responsibility to check our Policy each time before you access our Website for any changes.