Privacy Policy

INTRODUCTION

Policy prepared by: Catherine Mauch, Digital Project Coordinator
Updated on: 30/03/2021
Policy effective from: 10/08/2018
Review Date: 07/06/2021

Cool Earth needs to gather and use certain information about individuals. These can include donors, customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

Personal information means information which relates to a living individual who can be identified from that information such as names, e-mail addresses, personal home addresses, personal phone numbers, personal bank account details, personal description and photograph, etc. (“personal information”).

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Cool Earth (“we”, “our”, “us”) are committed to protecting and respecting personal information. We will treat personal information securely.

We are the data controller for the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

If you have any questions, comments and requests regarding your personal information (including how to object to us processing your personal information) please contact: [email protected].

If you are unhappy with how we handle your personal information, you can notify the Information Commissioner’s Office (ICO) by calling their helpline on: 0303 123 1113.

WHY THIS POLICY EXISTS

This data protection policy ensures Cool Earth:

1. Complies with data protection law and follow good practice.
2. Protects the rights of supporters, customers, staff and partners.
3. Is open about how it stores and processes individuals’ data.
4. Protects itself from the risks of a data breach.

DATA PROTECTION

The Data Protection Act 2018 & GDPR describe how organisations — including Cool Earth— must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

SHARING YOUR DATA WITH COOL EARTH

The following sections detail the various ways that you can share your data with Cool Earth and the personal data collected, the purpose(s) we use the data for and the legal basis for processing your data for the intended purpose(s).

In some cases legitimate interest is used as the legal basis and if you would like to know more about how we came to this conclusion please contact [email protected].

MAKING A DONATION TO COOL EARTH

This section sets out the personal information we collect about our donors, the purpose(s) we use your personal information for and the legal basis for processing your data.

PERSONAL INFORMATION COLLECTED

BANK ACCOUNT DETAILS

Card and bank account details are collected and passed to our payment processors (note that for security reasons and payment card industry (PCI) compliance; card and bank details are not stored in our systems).

DONATION INFORMATION

The amount, date, method, postal address and country of your donation.

CONTACT DETAILS

Your title, first name, last name and email address.

GIFT AID INFORMATION

Should you wish to claim gift aid on your donation we process your name, email, address, and declaration of eligibility.

WHAT WE DO WITH YOUR DATA

CARD & BANK ACCOUNT DETAILS

This data is used to process your donation. Note that for security reasons & PCI Compliance; card and bank details are not stored in our systems.

DONATION INFORMATION

This information is used as a record of your donation and to enable us to provide receipts and certificates of your donations. We also want to send the most effective messages that we can in the most efficient way possible, so in order to work out who to contact, what to say and when to get in touch, we analyse your donation information. We may also append generalised information from other sources; this information will not be specific to you. Analysing your information as just described is called “segmentation” or “profiling” and it helps us to provide people with the most relevant information in order to identify additional opportunities for them to get involved. We may also use the information provided in aggregate (so that no individuals are identified) for marketing and strategic purposes.

CONTACT DETAILS

1. Your contact details are used to provide a personalised receipt and so that we can address you personally should you have any questions related to your donation(s).

2. If you have provided your consent, your contact details are also used to provide you with updates on our projects and fundraising activities.

2a. We may also use your email address to link your record on our database with information on your use of Cool Earth’s website and demographic information gathered by Google Analytics. See the ‘Use of Cookies’ section for more information on the data collected and how we use it.

GIFT AID INFORMATION

This data is used to claim gift aid on your donation(s).

LEGAL BASIS

CARD & BANK ACCOUNT DETAILS

Necessary for the performance of a contract.

DONATION INFORMATION

Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your donation information for the purposes outlined and that your fundamental rights are not harmed in doing so.

CONTACT DETAILS

1. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your contact details for the purposes outlined and that your fundamental rights are not harmed in doing so.

2. Consent: On the basis of your consent only.

2a. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your contact information for the purposes outlined and that your fundamental rights are not harmed in doing so.

GIFT AID INFORMATION

In accordance with HMRC’s Gift Aid rules.

SUBSCRIBING TO COOL EARTH’S EMAIL UPDATES

This section sets out the personal information we collect about our subscribers, the purpose(s) we use your personal information for and the legal basis for processing your data.

PERSONAL INFORMATION COLLECTED

CONTACT DETAILS

1. Your first and last name

2. Your email address

WHAT WE DO WITH YOUR DATA

CONTACT DETAILS

1. We use your name so that we can address you personally when we get in contact.

2. We use this to send you our communications.

2a. We may also use your email address to link your record on our database with information on your use of Cool Earth’s website and demographic information gathered by Google Analytics. See the ‘Use of Cookies’ section for more information on the data collected and how we use it.

LEGAL BASIS

CONTACT DETAILS

1. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your contact details for the purposes outlined and that your fundamental rights are not harmed in doing so.

2. Consent: On the basis of your consent only.

2a. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your contact details for the purposes outlined and that your fundamental rights are not harmed in doing so.

MAKING A PURCHASE FROM COOL EARTH’S ONLINE SHOP

Please view our shop’s Privacy Policy here, to learn how coolearthshop.org collects, uses, and discloses your personal information when you visit or make a purchase from our shop.

CREATING A FUNDRAISING CAMPAIGN

This section sets out the personal information we receive from our third party processors when you create a fundraising campaign and the purpose(s) we use your personal information for and the legal basis for processing your data.

Please note these third parties are independent data processors and as such, are not subject to this privacy policy. However, they have been carefully chosen and we ensure that legal agreements are in place to govern how they use your information. You can read more about how these third party processors use your information in their privacy policies here:

JustGiving

Virgin Money Giving

Facebook

PERSONAL INFORMATION COLLECTED

CONTACT DETAILS

1. First and last name

2. Email address

3. Address

WHAT WE DO WITH YOUR DATA

CONTACT DETAILS

1. We use your name so that we can address you personally when we get in contact.

2. We may also use your email address to thank you for setting up your campaign and to provide you with useful information and tips for running your campaign.

2a. If you have provided your consent, your email address will also be used to provide you with updates on our projects and fundraising activities.

3. We may use your address to administer fundraising resources as well as notify you with relevant fundraising opportunities. Cool Earth does not send regular updates by post but if you would like to opt out of postal communications from Cool Earth please let us know at [email protected]

LEGAL BASIS

CONTACT DETAILS

1. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your name for the purposes outlined and that your fundamental rights are not harmed in doing so.

2. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your email address for the purposes outlined and that your fundamental rights are not harmed in doing so.

2a. Consent: On the basis of your consent only.

3. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your address for the purposes outlined and that your fundamental rights are not harmed in doing so.

SUBMITTING A CONTACT FORM TO COOL EARTH

This section sets out the personal information we collect when you submit a ‘Contact Us’ form to Cool Earth, the purpose(s) we use your personal information for and the legal basis for processing your data.

PERSONAL INFORMATION COLLECTED

CONTACT DETAILS

1. Your first and last name
2. Your email address

WHAT WE DO WITH YOUR DATA

CONTACT DETAILS

1.We use your name so that we can address you personally when we respond to your message.

2.Your email address is used to reply to your enquiry.

2a.If you have provided your consent, your contact details are also used to provide you with updates on our projects and fundraising activities.

LEGAL BASIS

CONTACT DETAILS

1. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your name for the purposes outlined and that your fundamental rights are not harmed in doing so.

2. This is not a marketing email so does not require your consent.

2a. Consent: Your email address will only be used to send you marketing emails if you have given your consent.

APPLYING FOR A JOB AT COOL EARTH

This section sets out the personal information we collect about our job applicants, the purpose(s) we use your personal information for and the legal basis for processing your data. Please reference our Job Applicant Privacy Notice for additional details.

PERSONAL INFORMATION COLLECTED

INTRODUCTION

Name and contact details including email, telephone and home address.

SKILLS AND EXPERIENCE

Education and previous employment details.

FURTHER INFORMATION

1. Disability status.

2. Legal entitlement to work in the UK.

REFERENCES

Names and contact details of two referees.

WHAT WE DO WITH YOUR DATA

INTRODUCTION

For the purpose of contacting you about your application.

SKILLS AND EXPERIENCE

For the purpose of evaluating your application only.

FURTHER INFORMATION

For the purpose of evaluating your application only.

REFERENCES

For the purpose of evaluating your application only.

LEGAL BASIS

Introduction

Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your information for the purposes outlined and that your fundamental rights are not harmed in doing so.

Skills and Experience

Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your information for the purposes outlined and that your fundamental rights are not harmed in doing so.

Further Information

1. Legal Obligation: We are legally obliged to ask about your disability status. This information will be treated confidentially and used only in accordance with the law.

2. Legal Obligation: We are legally obliged to ask about your entitlement to work in the UK.

References

Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to request this information for the purposes outlined and that your fundamental rights are not harmed in doing so.

BECOME A COMMUNITY OR BUSINESS PARTNER

This section sets out the personal information we collect about people who apply to become a Community or Business Partner, the purpose(s) we use your personal information for and the legal basis for processing your data.

PERSONAL INFORMATION COLLECTED & WHAT WE DO WITH YOUR DATA

1. This enquiry form asks for basic information about you and your organisation. We gather this information in order to start understanding each other and to assess the potential of exploring a partnership together. The information you provide will be stored securely by Cool Earth and will not be accessible by any third parties. This information will be stored by Cool Earth indefinitely, though by your request (you can email us at communitypartnerships[email protected] or [email protected]) we will anonymise or delete this data at any time.

2. If you give your consent we will also use your email address to send you our email updates.

LEGAL BASIS

1. Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process your information for the purposes outlined and that your fundamental rights are not harmed in doing so.

2. Consent: Your email address will only be used to send you marketing emails if you have given your consent.

SHARING PERSONAL INFORMATION

Depending on the context we may share your personal information with the following organisations:

1. Stripe Payments UK LTD, a company incorporated under the Companies Acts in England (Company Number: 08480771) with its Registered Office address at 9th Floor, 107 Cheapside, London, EC2V 6DN to process your donation and send you a receipt. For more information please see Stripe’s Privacy Policy.

2. Payment Solutions Limited trading as Smart Debit UK LTD, a company incorporated under the Companies Acts in England (Company Number: 03493808 ) with its Registered Office address at Windlesham Court, 51 Guildford Road, Bagshot, Surrey, GU19 5NG to process your donation and send you a receipt. For more information please see Smart Debit’s Privacy Policy.

3. PayPal (Europe) S.à r.l. et Cie, S.C.A. (R.C.S. Luxembourg B 118 349) is duly licensed as a Luxembourg credit institution in the sense of Article 2 of the law of 5 April 1993 on the financial sector as amended (the “Law”) and is under the prudential supervision of the Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier. For more information please see PayPal’s Privacy Policy.

4. Cool Earth Action USA, a charity in the USA (EIN-26-3688173) with its registered office address at One Hanson Place, 17D, Brooklyn , NY 11243 as we share our customer relationship management database in order to reduce administration time and cost. Access is granted to one individual who needs to record information in the database.

5. Dotdigital, a company incorporated under the Companies Acts in England (Company Number: 03762341) with its registered address at No 1 London Bridge, London, SE1 9BG if you submit an email address. For more information please see Dotdigital’s Privacy Policy.

6. The Adventurists, a company incorporated under the Companies Acts in England (Company Number: 5995303) with its Registered Office address at 14 Whitehouse Street, Bristol, BS3 4AY only where you have a pre-existing relationship with The Adventurists. For more information please see The Adventurist’s Privacy Policy.

7. Third Sector Design Ltd. a company incorporated in England and Wales (Company Number: 06939100). Registered Address at 2 Bell Meadow, Bickleigh, EX16 8RE, UK as we share our customer relationship management database for ongoing support and management. Access is granted to those who need to manage records in the database.

8. Time Technology, a company incorporated in England and Wales (Company Number: 02782004). Registered Address at Brook Street, Mint Street, Godalming, Surrey, GU7 1HE. Time Technology have access to our customer relationship management system as our CRM partner.

9. Launch Online, a company incorporated in England and Wales (Company Number: 08184190). Registered Address at 16 Blackfriars Street, Manchester, England, M3 5BQ. Launch Online remarket relevant content to Cool Earth’s supporters via Google Ads and social media platforms. They access Google Analytics to measure and analyse these results.

10. Teemill Tech Ltd., a company incorporated in England (Company Number: 07071956). Registered Office Address at Rapanui Clothing, Hooke Hill, Freshwater, Isle of Wight, England , PO40 9BG. Our shop passes information securely to a fulfilment partner to ship some orders. By shopping with us you agree to order data being stored according to the Teemill Tech Privacy Policy.

11. Shopify UK Limited, a company incorporated in England (Company Number: 11256480). Registered address 1 Bartholomew Lane, London, England, EC2N 2AX. Shopify has access to device information in order to optimise our shop site and order information required to process your purchase. For more information please see Shopify’s Privacy Policy.

12. FormAssembly, Inc. a company incorporated in the United States, located at 855 South College Mall Road, #339, Bloomington, Indiana 47401. FormAssembly is our web form platform. Forms submissions are processed in FormAssembly and integrated into Salesforce on Cool Earth’s behalf and per our instructions. For more information please see FormAssembly’s Privacy Policy.

13. GiveWP, an affiliate of Impress.org, LLC is a company incorporated in United States, located at 443 G Street, Suite #204, San Diego, California 92101. GiveWP is our donation portal with Stripe and PayPal as the payment gateways and processors, to process and maintain all financial transactions. For more information please see GiveWP’s Privacy Policy.

14. Salesforce UK Limited, a company incorporated in England (Company Number: 05094083). Registered address Floor 26 Salesforce Tower, 110 Bishopsgate, London, England, EC2N 4AY. Salesforce is our customer relationship management system where we securely store your information.

15. Fat Beehive Limited, a company incorporated in England (Company Number 03608544. Registered address 10a Lant Street, London, SE1 1QR. Fat Beehive is our web development agency and have access to data stored on our website and Google Analytics.

Appropriate  contractual agreements are in place to ensure all personal information is stored and processed securely.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF THE EEA

Cool Earth is an international charity and on occasion, your personal data may be transferred outside of the EEA. Such transfers will only occur where strictly necessary and either contractual clauses or data sharing agreements will ensure that your data will be processed with the same protections in place as in the EEA.

When donating the Cool Earth website the following payment processors may transfer and process your data outside of the EEA:

Stripe – Legal Basis: Necessary for the performance of a contract between you, the subject, and Stripe. Stripe is an active participant in the US Privacy Shield Scheme.

PayPal – Legal Basis: Necessary for the performance of a contract between you, the subject, and PayPal. Please see PayPal’s User Corporate Rules for information on where data may be transferred and processed and the Principles and Policies that are in place to ensure personal data is adequately protected.

EMAIL TRACKING

We only want to send emails to supporters who want to receive them. In order to do this we may track the open and click through rates on a campaign-by-campaign basis. This allows us to gauge whether our email content is relevant for our supporters and make decisions about who we should or should not contact via email.

LEGAL BASIS

Legitimate Interest: We believe based on our assessments that it is in our legitimate interests to process transactional data relating to how our supporters interact with our emails for the purposes outlined and that your fundamental rights are not harmed in doing so.

RETENTION PERIODS

Cool Earth is committed to not retaining data longer than is necessary for our purposes, as described in this policy, unless we are required to keep your personal data to comply with the law and any regulatory requirements. Deleting or anonymizing data which is no longer needed reduces the impact of potential data breaches. However, of course, this means that records of your previous interaction or support for Cool Earth may be no longer traceable back to you.

Website Usage

Data relating to your usage of Cool Earth’s website is automatically stored in Google Analytics and is available for 24 months. After that period has passed, only aggregate information is available to Cool Earth. This data helps us to optimise the website for all our users.

Submitting Data to Cool Earth

Contact data submitted to Cool Earth for example through the Contact Us form, or the Sign Up for Emails page will be retained for five years after your last interaction with Cool Earth. After this period has elapsed and providing there have been no further interactions in the meantime, the data will be anonymised on a yearly basis.

When a record is anonymised, all personal data is removed so that the record cannot be linked to any individual.

Donation data submitted to Cool Earth through our website or a third party (Virgin Money Giving or JustGiving for example) will be retained indefinitely. There are two main reasons for this. Firstly, audits may take historic transactions into account. Because we take financial accountability seriously we want to be able to produce this information if required. Secondly, we want to provide meaningful reporting to our donors.

This policy will always be overridden by a valid “right to be forgotten” request. Please see the Your Rights section for more information.

YOUR RIGHTS

Under the Data Protection Legislation you have certain rights in relation to your personal data:

1. You have the right to access the personal information we hold about you by making a subject access request in accordance with the Data Protection Legislation. We may charge a reasonable fee when a request is manifestly unfounded or excessive.

2. You have the right to have your personal data rectified if it is inaccurate or incomplete.

3. You have the right to have your personal information deleted in certain specific circumstances.

4. You have the right to restrict the processing of your personal information in certain specific circumstances.

5. You have the right to withdraw your consent at any time.

To use your rights, please contact: [email protected]

USE OF COOKIES

A cookie is a tiny element of data that our site can send to your browser, which enables the server to collect information from the browser and may then be stored on your hard drive. This small amount of information does not contain any private information stored on your computer. For more information about cookies, please go to http://www.cookiecentral.com.

The Cool Earth Action website uses cookies to identify you when you visit the website and to keep track of your browsing patterns, including how you came onto the site, and build up a demographic profile. To analyse the use of our website, Google Analytics generates statistical and other information about our website use by means of cookies. Google stores this information, to learn more please see their Privacy Policy. This data is anonymous in that it is not linked to any other data we hold about you. Our use of cookies also allows registered users to be presented with a personalised version of the site, carry out transactions and have access to information about their account.

You can access our website without disclosing your personal data but if you set your web browser to disable cookies altogether, this will restrict your use of the website.

For more information on the specific cookies Cool Earth uses please see our full Cookie Policy.

ADVERTISING

So that any advertising we engage in is as effective as possible, we make use of Google and Facebook services to create audiences where we focus our efforts. These audiences are created based upon use of our website and information individuals have shared with Google and Facebook.

For more information please see our Cookie Policy.

DISCLOSURES

When you provide us with personal information you are sharing that information with us alone unless stated otherwise. We will only disclose personal information to successors in title to our business and suppliers we engage to process data on our behalf. We will not share your information with any other third parties, outside of those specified in this policy, unless you opt-in and authorise us to do so.

OTHER WEBSITES

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

CHILDREN’S PRIVACY

No information should be given on this website by children under the age of 13 without prior parental consent. No sharing of data collected from children with any third parties is permitted at any time under any circumstances and all applicable laws with respect to data collection from children are followed.

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