This policy applies to current and former contacts (including, but not limited to, WW organisers and makers, artists and partner organisations), vendors, other third parties with whom we work and other persons.
Data Privacy Manager: Lucy Reeves Khan
Company Name: Window Wanderland CIC
Address: 35 Nevil Road, Bristol BS7 9EG
- What personal data we collect, and how / why we use it
- When you sign up to be an organiser
- When you sign up to be a participant
- When you sign up to ‘volunteer to help’
- When you sign up to our newsletter / mailing list
- Photographs and films
- Taking part in an event or workshop
- Who we share your information with
- How we store and protect your personal information
- Your data protection rights
- Regulatory Contact Details
What personal data we collect, and how / why we use it
“Personal data” is any information about a living individual from which they can be identified such as name, ID number, location data, any online identifier, or any factor specific to the physical, physiological, genetic, mental, economic or social identity of that person. It does not include data where any potential identifiers have been removed (anonymous data) or data held in an unstructured file.
When we refer to “processing,” this means such processes as collecting, using, storing, transferring, disclosing, altering, or destroying personal data.
WWCIC will only collect your personal data to ensure we can keep you informed about our work, projects, events and online shop. We will not collect or keep personal information about you unless we need it. We will not collect more information than we need and we will not keep it longer than we need to.
You can ask us to remove your personal information at any time.
We also collect, use and share aggregated data such as access to a specific website feature, statistical or demographic data for reports and funding applications to demonstrate where events have taken place and how many people have participated. 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.
Below outlines how we use your data when you interact with us in different ways:
When you sign up to be an organiser
When you sign up as an organiser you will be required to register for an account, where we ask for your:
- Postal address
- Phone number(s)
- Email address (we’ll suggest you create a new email address specifically for your neighbourhood project).
We process this information to provide our service to you under the lawful bases of performance of a contract, and necessary for our legitimate interests (to keep records of registrations, to provide registration confirmations and to ensure the required services are available to you).
We use the information specifically to:
- Provide the service to you – creating an organiser account on our system giving you access to our resources and use of our messaging system for volunteers / queries to be directed to you.
- Process payments (Please note we do not store any Credit Card or other payment information).
- Send you administrative messages and other information to do with your event
- To enable us to administer the project
- To fulfil product orders placed on the website and ship items to the right address
- To fulfil registrations and send required information
When you sign up to be a Participant
When you sign up to take part in an event (make a window), we only ask for your address and your email (we do not ask for your name).
We process this information to provide our service to you under the lawful bases of performance of a contract, and necessary for our legitimate interests (to keep records of registrations, to provide registration approvals / confirmations and to ensure the required services are available to you, to enable organisers to provide you with event information).
We use the information specifically to:
- Add your address to the online map for your chosen Window Wanderland event
- Enable the event organiser to contact you with any information about the event via our system (Please note that you will always receive emails from event organisers about events you sign up to. However, the organiser will never see your email address unless you contact them directly)
- Keep your email on record so that you can be contacted by future organisers for participation only.
You will NOT be automatically added to following events. As you have signed up with your own account you can choose to remove yourself completely at any time.
We will never send you unsolicited email or pass on your details to anyone else.
Your email is not shown to the organiser at all except if you tick the ‘volunteer to help’ button – your email will be visible by the organiser if you do this.
When you sign up to ‘volunteer to help’
When you sign up to take part in an event , you also get an option to tick a ‘volunteer to help’ button. Your name and email are then sent to the organiser so they can get in contact with you.
We process this information to provide our service to you under the lawful bases of performance of a contract, and necessary for our legitimate interests (to keep records of volunteer registrations, to facilitate communication with organisers).
We use the information specifically to:
- Enable the organiser to contact you with information regarding volunteering for the event.
When you sign up to our Newsletter / Mailing List
If you sign up to our newsletter we ask for your name and email address. You are also given the option to opt into our mailing list when signing up as an organiser or participant. Our occasional newsletter is sent out when we have something to share, we aim to make it relevant, keep it short and make you smile.
We process this information to facilitate your request to receive our newsletter (under the lawful basis of consent). We use the information specifically to:
- Send you emails about upcoming events and other Window Wanderland information we think you will be interested in.
Photographs and films
We sometimes take photographs and film at our sessions and events.
Any images are processed on the lawful basis of consent; Before taking any images we will ask for verbal consent from individuals, parents/carers, and anyone else we will be filming. Once the activity is over we then ask for written consent from the same people so that the photographs and films may be used by WWCIC for our website, flyers, publicity and social media.
If you are unhappy about this, please tell us. We will make sure that we do not take any photographs/films of yourself and that you will not appear in any group photographs or films that may be used in our publicity.
Taking Part in a Event or Workshop
In cases where you are attending one of our online or physical events or workshops, we may ask for information about you or your needs (for example, information on your disabilities, carers, dietary requirements or emergency contacts).
We process this information to ensure the safety of our participants during events or workshops (under the lawful basis of vital interests). We use the information specifically to:
- Ensure any catering that is supplied is safe for participants to consume
- Facilitate any access requirements participants may have
- Have emergency contact information available to our session leaders if they require it in the event of an emergency.
“Cookies” are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to recognise you when you visit.
It is possible to switch off cookies by setting your web browser preferences. You can also delete cookies by clearing your web browser’s cache (history).
Who we share your information with
All the personal data WWCIC has is only processed by our staff.
We don’t share the information that is provided to us except:
- with third party service providers, such as our system hosting providers (see table below for more information), or distribution mailing companies for specific events. We make sure anyone who provides a service for us meets our standards for data protection and security, and have data processing agreements in place to ensure this. They will not use your data for anything other than the service that they are providing. These companies provide services to us so that we are able to fulfil our obligations to you or, where we are able to send you marketing information, to do so;
- if we have a legal obligation to disclose your information (for example, if a court orders us to);
In addition we use the following data processors to enable us to collect, process and securely store the data we obtain:
|SendinBlue||Customer relationship – Sendinblue is the online platform we use to coordinate our projects and send out our email communications. It’s also the platform that powers your online account when you register.||https://www.sendinblue.com/legal/privacypolicy/|
|Paypal||Payment – We use paypal to process all financial transactions||https://www.paypal.com/uk/webapps/mpp/ua/privacy-full|
|SquareUp||Customer relationship – this is our online shop sales platform for products and workshops. We use this site to process customer data and financial transactions.||https://squareup.com/gb/en/legal/general/privacy|
|Customer relationship – enquiry forms, organiser feedback and other surveys.||https://policies.google.com/privacy?hl=en-GB|
|Xero||Customer relationship – we use Xero to invoice and process and record financial transactions..||https://www.xero.com/uk/about/legal/privacy/|
How we store and protect your personal information
Your information is securely stored on a secure cloud-based service (SendinBlue) and, at times, on a back-up hard drive. Physical documents containing data will be stored in a single secure location.
We may transfer your data to organisations based outside the UK (such as sendinblue and paypal). When we do this we will ensure that we only use organisations who have sufficient safeguards in place to ensure your data rights are maintained.
We keep personal information, such as name, address, email and contact numbers for 6 years from the last agreement we hold with you, or 2 years from the last date you expressed interest in our service. Exceptions include if monies were still outstanding, as contact details will remain on file until all aspects of the contract, such as payment, have been fulfilled. We will then dispose of your information by shredding physical copies and permanently deleting online files.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at firstname.lastname@example.org if you wish to make a request.
Regulatory Contact Details
Depending on where you are resident or otherwise located, you have the right to make a complaint any time to the relevant national supervisory authority for data protection issues.
In the UK, for example, you can make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We are registered with the ICO:00015028236.
We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance at Window Wanderland CIC email@example.com.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Helpline number: 0303 123 1113