Changes to data protection law
The law in relation to data protection changed on the 25 May 2018 when the General Data Protection Regulation came into force in the United Kingdom and across Europe.
When you are using our website, the innocent foundation is the data controller (referred to as “the foundation” “we”, “us” or “our” in this privacy notice). Our registered office is at Fruit Towers, 342 Ladbroke Grove, London, W10 5BU.
When we refer to our website, we mean our website at https://www.innocentfoundation.org
We may collect, store and transfer personal information about you in the following ways:
Data you give to us:
Data we collect when you use our services:
Data from third parties we work with:
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
Identity data – name, username, marital status, title, photographs, date of birth and gender.
Contact data – billing address, delivery address, email address or telephone numbers, social media addresses.
Technical data – internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile data – feedback and survey responses.
Usage data – information about how you use our website.
Marketing and communications data – your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any special categories of personal information about you. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
We are only allowed to use personal information about you if the law allows us to. We have set out in the table below the personal information which we collect from you, how we use it, and the legal basis on which we rely when we use the personal information.
Most commonly, we will use your personal data personal information in the following circumstances:
|Purpose and Activity||Type of Data||Our lawful basis for processing including our legitimate interests (if applicable)|
|Details of interactions with us through email, letter, telephone, social media or popping into Fruit Towers, including sending you relevant, personalised communications by post in relation to updates, offers, services and products. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made and how and when you contact us.Handling the information, you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout.||full name, address, email address and copies of your communication with us||We do this on the basis of our contractual obligations to you and our legitimate interests in providing you with the best service and understanding how we can improve our service, products and business based on your experience.We also use this information to protect our business from fraud and other illegal activities.|
|Login in your details on attendance and CCTV operation when you visit us at Fruit Towers||Name and images of you||We do this on the basis of our legitimate business interests and legal obligation to comply with the laws and regulations.If we discover any criminal activity or alleged criminal activity through our use of CCTV, we will process this data for the purposes of preventing or detecting wrongful and unlawful acts. We aim is to protect the individuals we interact with from criminal activities.Also, to generally protect our visitors, employees, premises and assets.|
|Webnews and newsletters to keep you informed about relevant products and services including tailored special offers, promotions, events, competitions and so on.||Full name, address, email address and date of birth. Date of birth may be collected to ensure we’re not contacting anyone under the age of 16, email address and name is required so that we can send you our newsletter.||This will be subject to your prior consent. If we did not have this information then we wouldn’t be able to contact you. You can of course, let us know at any time when you do not want to receive this information.|
|Displaying the lovely things you send us on our wall of love||Name, photographs||This will be subject to your prior consent.|
|Manage our relationship with you, including notifying you about changes to our terms or privacy notices||Full name, address, email address||In this instance we would not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal information for these purposes, we would be unable to comply with our legal obligations.|
|If partaking in campaigns and competitions (such as the Big Knit and the Big Grow).If you’ve given us permission, we’ll contact you about future campaigns, or send you our newsletter.||Full name, address, email address and date of birth. Usage, technical and marketing data
For School involved campaigns we may also ask for school details such as school name, email and teacher email address.
|This is necessary for legitimate business interest and where appropriate we will also obtain consent. For campaigns like the Big Knit If we don’t have this information then we’re unable to confirm receipt of your hats and say thank you to you for getting involved.For competitions we wouldn’t be able to choose you as a winner and send you a prize if we’re not able to use your data.Where you have obtained specific consent, you may at any time, let us know that you do not want to receive the information.|
|To send you survey and feedback requests to help improve our services.||Name, address, email address, usage data and marketing data||These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||Identity, contact, and technical data||This is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).Necessary to comply with a legal obligations.|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.||Technical and usage data||This is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).|
|To make suggestions and recommendations to you about goods or services that may be of interest to you.||Name, address, email address, technical, usage and profile data||This is necessary for our legitimate interests (to develop our products/services and grow our business).|
|To invite you to an event hosted by us||Name, email address, other identity data (such as allergens if we are serving food) and contact data so we send you the invite||This is necessary for our legitimate interests (to build a business or networking relationship with you within a specific geographic location to enable us to strengthen ties within the community and to develop our business).|
|Applying to a vacancy on our website||Name, address, email address and other information on your curriculum vitae||We will obtain your appropriate consent.|
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org or you can write to our DPO at Fruit Towers, 342 Ladbroke Grove, London, W10 5BU.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us email@example.com or you can write to our DPO at Fruit Towers, 342 Ladbroke Grove, London, W10 5BU.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We require all organisations who we share your data with to respect the security of your personal information and to treat it in accordance with the law. We do not allow any of our service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services and entering into competitions). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit.
The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway.
We do not transfer your data outside of the EEA. However, we may use third party services providers that do, in which case, if they do transfer your personal information outside the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA and will ensure adequate safeguarding measures are in place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
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 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.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator (including the ICO) of a breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information (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.
We may use your personal information to tell you about relevant goods or services and any upcoming offers.
We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.
You can ask us to stop sending you marketing messages at any time – you just need to contact us at firstname.lastname@example.org or use the opt-out links on any marketing message sent to you.
We will get your express opt-in consent before we share your personal information with any company other than outside our group of companies for marketing purposes. You can ask a third-party company to stop sending you marketing messages at any time, by adjusting your marketing preferences in relation to that company or by using the opt-out links on any marketing message sent to you.
Where you opt out of receiving marketing messages, this will not apply to personal information provided to us as a result of purchasing our goods or services or any other transaction between you and us.
This website is not intended for children under the age of 16 and we do not knowingly collect data relating to children. We encourage parents and legal guardians to monitor their children’s internet use. If you have reason to believe a child under the age of 16 has provided personal information to us through our service please contact us at email@example.com or you can write to the DPO at Fruit Towers, 342 Ladbroke Grove, London, W10 5BU.
Under certain circumstances, you have rights under data protection laws in relation to your personal information. Information about your rights are as follows:
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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. 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 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information 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 information. This enables you to ask us to suspend the processing of your personal information 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.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. Please contact us at firstname.lastname@example.org if you want to withdraw your consent or you can write to the DPO at Fruit Towers, 342 Ladbroke Grove, London, W10 5BU.
No Fee Usually Required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please let us know if you are unhappy with how we have used your personal information by contacting us at email@example.com. If you want to you can write to the DPO at Fruit Towers, 342 Ladbroke Grove, London, W10 5BU.
You also have a right to complain to the Information Commissioner’s Office. You can find their contact details at www.ico.org.uk. We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.