1. Introduction

1.1     We are committed to safeguarding the privacy of our website visitors and in this policy we explain how we will handle your personal data.

1.2     This policy applies only to the use of data obtained via our website. Our Data Protection Policy and Procedures contain full information on how we use and protect personal data collected by other means, e.g. the provision of services and can be found here.

1.3     We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4     This policy was last updated on 22 June 2018.

2. Credit

          This document was created using a template from SEQ Legal (http://www.seqlegal.com).

3. How we use your personal data obtained via our website

3.1     In this Section 3 we have set out:

(a)      the general categories of personal data that we may process;

(b       the purposes for which we may process personal data; and

(d)      the legal bases of the processing.

3.2     We may process data about your use of our website (‘usage data’). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3     We may process your account data (‘account data’). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.  The legal basis for this processing is consent.

3.4     We may process your information included in your personal profile on our website (‘profile data’).  The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.

3.5     We may process information that you post for publication on our (‘publication data’). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

3.6     We may process information contained in any enquiry you submit to us regarding products and/or services (‘enquiry data’). The enquiry data may be processed for the purposes of offering services to you. The legal basis for this processing is our legitimate interests, namely the provision of products and/or services about which you have enquired.

3.7     We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website (‘transaction data’). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.8     We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (‘notification data’). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.9     We may process information contained in or relating to any communication that you send to us (‘correspondence data’). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.10   We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.11   In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.12   Please do not supply any other person's personal data to us, unless we prompt you to do so, in which case we will abide by the conditions detailed in our Data Protection Policy and Procedures.

4. Providing your personal data to others

4.1     Financial transactions relating to our website and services may be handled by our payment services providers, Stripe and Go Cardless.

          We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds You can find information about the payment services providers' privacy policies and practices at:

-         Stripe (URL https://stripe.com/gb/privacy)

-         GoCardless  (URL https://gocardless.com/legal/privacy/)

4.2     Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

  • Your data will be made available to our website provider
  • The data that may be available to them include any of the data we collect as described in section 3 above.
  • Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
  • They will store your data for a maximum of 7 years.
  • This processing does not affect your rights under sections 10 or 16 of this privacy policy

 4.3     In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. International transfers of your personal data

5.1     You acknowledge that personal data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1     This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2     Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Full details of our data retention and deletion policy can be found in our Data Protection Policy and Procedures.

6.3     Personal data obtained via our website will be retained by our website provider for 7 years.

6.4     Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1     We may update this policy from time to time by publishing a new version on our website.

7.2     You should check this page occasionally to ensure you are happy with any changes to this policy.

8. Your rights

          Please see our Data Protection Policy and Procedures.

9. Third party websites

9.1     This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them. If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data

9.2     We operate a number of social media pages, including Facebook, Twitter and You Tube. Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

10. About cookies

10.1   A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

10.2   Cookies may be either ‘persistent’ cookies or ‘session’ cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

10.3   Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

11. Cookies that we use

We use cookies for the following purposes:

(a)      authentication - we use cookies to identify you when you visit our website and as you navigate our website’;

 (b)     status - we use cookies to help us to determine if you are logged into our website;

(c)      personalisation - we use cookies to store information about your preferences and to personalise the website for you;

(d)      security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services;

 (f)     analysis - we use cookies to help us to analyse the use and performance of our website and services and

(g)      cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally

We may use the following cookies:

          _ga, _gid, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv. cc_cookie_accept, ASP.NET, _SessionI, ARRAffinity, MemberLoggedIn, ai_session and ai_user, DisplayName,  IDE,  DSID, _ct_rmm,  __cfduid.

12. Cookies used by our service providers

          We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. This data may be stored outside the EU, under a EU-US Privacy Shield agreement. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy 

13. Managing cookies

13.1   Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.

13.2   If you block cookies, you will not be able to use all the features on our website.

14. Our details

14.1   This website is owned and operated by Staywell, which is the working name for Age Concern Kingston upon Thames.

14.2   Age Concern Kingston upon Thames is a company limited by guarantee, registered in England and Wales under registration number 2272550 and our registered office is at Raleigh House, 14 Nelson Road, New Malden, KT3 5EA.

14.3   Our principal place of business is at Raleigh House, 14 Nelson Road, New Malden, KT3 5EA.

14.4   You can contact us:

(a)      by post, to the postal address given above;

(b)      using our website contact form;

(c)      by telephone, on the contact number published on our website; or

15. Data protection registration

15.1   We are registered as a data controller with the UK Information Commissioner's Office.

15.2   Our data protection registration number is Z8935272.

16. Complaints

16.1   If you have a complaint about us, or the treatment of your data, you can contact the Charity Commission. The Charity Commission is the independent watchdog for charities.  You can make a complaint about a charity on their website at www.charity-commission.gov.uk.

16.2   If you've got a complaint about our fundraising activities you can also complain to the Fundraising Regulator.  To find out how to go about making a complaint, go to the Fundraising Regulator website at https://www.fundraisingregulator.org.uk/make-a-complaint/complaints/