PRIVACY NOTICE & COOKIES POLICY
ENDING IMPUNITY takes your privacy very seriously and is committed to protecting it. We comply with the UK Data Protection Act 1998 (DPA) and the General Data Protection Regulations 2018 (GDPR). We will only collect and use information about you lawfully. This Privacy Notice and our Cookies Policy explains how we collect and store your information. It tells you about your privacy rights and how the law protects you.
Who we are
ENDING IMPUNITY LTD (ENDING IMPUNITY) is a charitable company limited by guarantee incorporated in England & Wales registered company number 12424358 with its registered office address at 264 Banbury Road, Oxford, Oxfordshire, United Kingdom, OX2 7DY. ENDING IMPUNITY’s registration with the Charity Commission for England & Wales is pending under application number 5163178.
The website at www.endingimpunity.com is owned by ENDING IMPUNITY (our Website). ENDING IMPUNITY does not publish or operate any other websites at any other domain addresses. Any websites on any other domain address using the ENDING IMPUNITY name, or any similar or derivative name, or purporting to be, or to represent, ENDING IMPUNITY, is not owned, operated, or authorised by ENDING IMPUNITY.
What information we may collect
ENDING IMPUNITY may collect information about our beneficiaries, clients, supporters, donors, fundraisers, contributors, volunteers, and users of our Website and social media channels (for example Twitter, Facebook, Instagram, YouTube).
We may collect:
Personal information:Name, address, email address, telephone number, date of birth, age, and gender.
Your preferences: what you’ve told us about whether, and if so how we may contact you (for example by email, telephone, SMS/text message, mail) and what information you’d like to receive from us (for example, notifications of news items and new blog posts, newsletters, publications, event announcements and invitations, information about our fundraising campaigns).
Your interests: We may collect information that you give to us about your interests.
Your professional titles, qualifications, employment status, and affiliations: We may collect and store other information about you including your professional titles and qualifications, your employment, and affiliations with relevant interest groups.
Payment information:We may collect your bank account details including direct debit, credit card, and debit card information, when setting up donations and processing card payments, and details about your taxpayer status for the purpose of claiming Gift Aid.
Information about your support for ENDING IMPUNITY.We may collect and process information about your support for and communications with ENDING IMPUNITY including:
- (i) contact and communication information from or with you including by submission of information via online forms, by email, SMS, text message (including via platforms such as WhatsApp, Signal, Telegram), mail, telephone, or in person
- (ii) information about your donations to ENDING IMPUNITY
- (iii) information about events (including online events) that you request information about, contribute to, register for, or attend;
- (iv)information about your volunteering to support ENDING IMPUNITY;
- (v) any other information you give to ENDING IMPUNITY.
Website information: details of your visit to our website, including your IP address.
Sensitive information
Sensitive information means information revealing or concerning: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); health; a person’s sex life; or a person’s sexual orientation.
ENDING IMPUNITY will not collect or use your Sensitive Information unless:
- (i) you have given it to us;
- (ii)you have given us your express consent to collect and use it; and
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(iii)collecting and using your Sensitive Information is necessary and justified, for example
- to enable us to provide you with a service that you have requested ENDING IMPUNITY to provide to you; and/or
- to further a case investigation or legal complaint or other activity falling within our charitable objects.
Any Sensitive Information that we do collect will be kept secure, will only be used for the purpose(s) for which you have given us your express consent, and will not be kept for any longer than necessary for those purposes and in accordance with your consent.
For the avoidance of doubt, any Sensitive Information relating to case investigations, and/or which might be evidence in legal complaints or legal proceedings, may be subject to additional case-specific safeguards and consents unless we are required to disclose by general law or under court order.
The legal basis on which we may collect and use your information
ENDING IMPUNITY can, and will, only collect and use your information if there is a legal basis under the DPA and the GDPR. The legal bases on which we may collect and use your information will depend on the type of information, and the circumstances. Generally, the legal basis will fall within one or more of the following categories:
Consent:you have given clear consent for ENDING IMPUNITY to process your information for a specific purpose. This could include, for example:
- (i)you sign up via an online form through our Website to receive information such as newsletters, updates, and event notifications, and you tick a box to ‘opt-in’ to allow us to collect and use your information for that purpose
- (ii)you sign up to a log-in account to allow you to access a ‘members’ area of our website, and tick an opt-in box allowing us to use your information for that purpose
- (iii) you submit materials to our website, including blog posts, news items, or comments, and tick an opt-in box to allow us to use your information for that purpose
- (iv) you have given specific express consent for us to collect and use Sensitive Information
Contract: collecting and using your information is necessary for a contract we have with you, and/or because you have asked ENDING IMPUNITY to take specific steps before entering into a contract.
Legal obligation: the processing is necessary for ENDING IMPUNITY to comply with the law (not including contractual obligations). This could include a potentially wide range of legal obligations, pursuant to which ENDING IMPUNITY is legally required to collect, and/or process, and/or potentially to disclose:
- (i) information about suspected crimes, including terrorism offences, money-laundering, tax evasion, bribery, criminal fraud, child abuse, or other serious offences
- (ii) information required to comply with companies law, charity law, tax laws, and other laws relevant to governance and compliance for charitable companies registered in England & Wales
- (iii) information required to be collected and/or processed or disclosed by specific order of a court of competent jurisdiction.
Vital interests:the collection and use of the information is necessary to protect a person, or people, from serious harm. This legal justification, on its own, would be an exceptional basis for ENDING IMPUNITY to use your information. We would only ever rely on this legal basis alone in the unlikely event that:
- (i)there was no other legal basis for collecting and using your information; and
- (ii)ENDINGY IMPUNITY has received credible and reliable information that there is a genuine emergency involving a possible threat to life, or serious harm, to you or any other person; and
- (iii)on an objective assessment of information and evidence available to us at the time, and taking into account specific facts and circumstances, any delay in seeking your consent or your contractual agreement, or relying on any other legal justification for collecting and using your information, could result in serious harm to you or any other person.
Legitimate interests:the processing is necessary for ENDING IMPUNITY’s 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. Generally, we will rely on this legal basis jointly with other legal bases. So, for example, if you have signed up to the Website and consented to receive newsletters and updates, we might rely on that consent, together with legitimate interest, in sending you notification of that we are launching new fun ad raising campaign, inviting you to donate, share or participate. We will only rely on the ‘legitimate interest’ legal basis relating to non-sensitive matters. This may include for example internal administration and management, evaluation, monitoring, and analysis of our impact, fundraising, campaigning, and marketing activities.
How we collect information
We may collect information from you in a variety of ways.
For example:
- (i)when you interact with our Website or visit our social media platforms such as Twitter, Facebook, Instragram, Youtube;
- (ii)when you submit on-line forms, or contact us by email, telephone, mail, or through other media, including when you sign up to receive newsletters and updates, when you make a donation, or volunteer to support us, we may collect information, such as your name, address, email address, and telephone number;
- (iii)through cookies on our Website (please see the Cookies Policy below);
- (iv)when you contact us through any means with information about legal cases and investigations or other aspects of our work;
- (v)we may receive information about you from other sources. This includes for example information shared with us by third parties such as crowd funding platforms that you have donated to us through. We may also obtain information about you that is freely available in the public domain about you.
How we use your information
We collect information that we need, and that we believe would be useful, for the purposes of furthering our charitable objects and mission. These purposes include:
- (i)providing advice, support, services, or information that you have requested from us;
- (ii)management and administration of information about your support for us, including contributions to our Website, reports and publications; information in support of case investigations and legal actions; your voluntary support, fundraising activities, and donations, including managing Gift Aid;
- (iii)complying with laws and regulations;
- (iv)investigating and pursuing legal actions and complaints;
- (v)for internal administrative purposes, including keeping a record of your interactions and communications with us;
- (vi)communicating with you and giving you information about ENDING IMPUNITY’s work, services, and activities, fundraising campaigns, and any about any other products or services that we provide;
- (vii)giving you access to and managing your communication preferences;
- (viii)to keep a record of your consent to use your data for data processing, including direct-marketing purposes or newsletter circulation lists. If you have not consented to the use of your information for such purposes we will retain your name, home address and email address on a suppression list to ensure we do not continue to contact you.
- (ix)ensuring our Website content is delivered effectively for you and for your computer/mobile device; and
- (x)monitoring our impact and the effectiveness of our services by seeking your feedback.
How we store your information
For financial and technical reasons we may, on occasion, need to use the services of a supplier outside the European Economic Area (EEA). If so, we take all reasonable steps to ensure that your information is held in compliance with the DPA and the GDPR. By submitting your personal information, you agree to this transfer, storing or processing at a location outside the EEA. We will take all reasonable steps to ensure that your data is kept secure and in accordance with this Privacy Notice.
We will keep your information for as long as we need to, for use in accordance with this Privacy Notice. The duration for which we may retain your information will take into consideration our legal obligations and tax and accounting rules.
Who we may share your information with
We will not share your personal information with any third parties except as follows:
- (i) So that ENDING IMPUNITY’S trustees, staff, volunteers, third party consultants and contractors, or other service providers acting on our behalf, can access and use your personal information for purposes for which you have provided the information to us. All such third parties are required to enter into legally binding contracts and/or codes of conduct including appropriate confidentiality clauses. We will not give third parties any rights to receive or use your personal information except under our instructions and in accordance with this Privacy Notice.
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(ii)The only times we will pass your details to anyone else would be:
- a.to allow payment providers to complete transactions;
- b.to organisations in the payment card industry to prevent online fraud;
- c.if we are required to do so by any law or court order;
- d.if you are a beneficiary or client, and the details are provided to others who are working with us on your case;
- e.you have given us consent to do so; or
- f.where ENDING IMPUNITY and/or substantially all of its assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets.
How we keep your information safe
ENDING IMPUNITY takes data security very seriously. We deploy robust measures to ensure our Website, and our physical and technical systems are secure. We take appropriate precautions to protect all personal information we keep on our databases, including using encryption, and monitoring access to our secure networks and systems.
We do not accept direct payments through our Website. We may use links to third party donation platforms such as Go Fund Me, Virgin Giving, Just Giving and similar charitable giving platforms. ENDING IMPUNITY does not have access to your payment information when you donate through the links on our Website via those platforms. These platforms have their own secure systems for processing your payment information, such as your credit card or debit card details. ENDING IMPUNITY is not responsible for, and cannot accept liability for, security of those third party platforms.
Despite our best efforts to protect your personal information electronically, security of information sent over the internet cannot be guaranteed and may be illegally intercepted or changed after it has been sent. ENDING IMPUNITY cannot accept liability for this if this happens.
Our Website and social media
By using our Website, social media pages or providing your information you consent to our collection and use of the information you provide in the ways set out in this policy. If you do not agree to this policy please do not use our website, social media pages or services.
We use cookies on our Website to improve functionality and to track information about how visitors use the Website. More information on cookies can be found in the Cookies Policy below.
We cannot provide a 100% guarantee of the security of any information you transmit to us through our Website. We do have strict procedures and security features to protect your information and prevent unauthorised access.
We use third parties to secure, maintain and modify our Website and social media platforms, and to manage our IT systems.
Our Website contains links to third party resources such as other Websites, and social networking sites including, for example, Twitter, Instagram, Facebook and YouTube. ENDING IMPUNITY does not control and is not responsible for the privacy policies and practices of these other sites.
Children and parents
We collect data about all users of and visitors to our Website regardless of age, and we anticipate that some of those users and visitors may be children (persons under 18 years of age). ENDING IMPUNITY does not knowingly collect, use, or distribute children’s personally identifiable information. If you are under 18, you may use our Website with consent from a parent or guardian. We encourage parents to talk to their children about safe and responsible use of the Internet.
Your rights
This section tells you about your legal rights concerning your information (data protection rights).
- (i)The right to be informed: you have the right to be told about how we collect and use your information. This Privacy Notice informs you how we collect and use your information. You can also contact us with any questions that you have.
- (ii)The right of access: you have the right to access and receive a copy of your information that ENDING IMPUNITY has collected, and other supplementary information. If you wish to exercise your right to access your information, you can file a ‘subject access request’ with ENDING IMPUNITY.
- (iii)The right to rectification: You can challenge the accuracy of the information that we hold and you have the right to ask us to update, correct, or amend your information if it is wrong.
- (iv)The right to erasure: This is also known as ‘the right to be forgotten’. You can ask us to delete your information from our records.
- (v)The right to restrict processing: You have the right to tell us to limit how we use your information, for example you can tell us that you do not want us to contact you, or you can tell us how we can contact you, and with what information.
- (vi)The right to data portability this means that you have the right to get your information from us in a way that is accessible
- (vii)The right to object: You can object to how we use your information in some circumstances, such as use of your information for marketing purposes
- (viii)Rights in relation to automated decision making and profiling: This right concerns automated decision-making and profiling using your information. We do not use your information for automated decisions or profiling.
- (ix)Your right to raise a concern: You have the right to raise a concern or complaint about the way in which your information is being used-see ‘Complaints’ below.
You can contact us about your rights by email, telephone, or by letter (see ‘How to contact us’ below). You can find out further information about your rights from the Information Commissioner’s website at https://ico.org.uk/your-data-matters/.
Complaints
If you are not happy with our Privacy Notice, or if you have any complaint about how we collect and use your information, then you should tell us (see ‘How to contact us’ below).
We will make every reasonable effort to resolve your complaint, including by engaging in good faith in a process of mediation.
If you are in any way dissatisfied about how we collect or use your personal information, or how we respond to any question or complaint, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/.
Updates to this Privacy Notice
We may update this Privacy Notice periodically. We will notify you of any significant changes, in accordance with your communications preferences, and by posting a notice on our Website. By continuing to use our Website you will be deemed to any accepted changes to this Privacy Notice.
How to contact us
If you have any questions about this Privacy Notice, or your information, you can contact us by:
- email at info@endingimpunity.com
- writing to Ending Impunity Ltd, Clarendon House 2nd Floor, 52 Cornmarket Street, Oxford OX1 3HJ
- telephoning us on 01865 238254.
Last updated: 19 August 2021,