1. INTRODUCTION

African Development Choices (ADC) respects your privacy and is committed to protecting your personal data.

This privacy notice aims to give you information on how ADC collects and processes your personal data through your use of its website africandevelopmentchoices.org, including any data you may provide through this website when you sign up to our newsletter or utilise our services. African Development Choices is the data controller and we are responsible for keeping your personal data safe.

This website is not intended for children and we do not knowingly collect data relating to children. Therefore, by providing your data you are confirming to us that you are over the age of 13. ADC/we/our/us refers to African Development Choices, a company limited by guarantee registered in England at our registered office at Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified for example, name, address, phone number, email address, age, National Insurance number, Social Media profile, IP address etc. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data – may include first name, last name, username or similar identifier and title.
  • Contact Data – may include billing address, delivery address, email address, social media handle and telephone numbers.
  • Technical Data – may include data about your use of our website such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, page views and navigation paths, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data – may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data – may include information about how you use our website and any other online services and any data that you post on our website or Social Media platforms.
  • Marketing and Communications Data may include your preferences in receiving marketing communication from us and our third parties. This may also include communication that you send to us whether through the contact form on our website, through email, text message, social media or any other communication channel. You can change your mind about receiving marketing communication at any time by checking or unchecking relevant boxes to amend your marketing choices by following the “unsubscribe” link in our newsletter or by contacting us by email at privacy@africandevelopmentchoices.org Where necessary, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

We may also collect, use and share Aggregated Data such as statistical or demographic data for analytical purposes. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 processed in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your 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). Nor do we collect any information about criminal convictions and offences.

  1. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your identity, contact and other data by filling in forms or by corresponding with us via our website, by post, phone, email or otherwise. This includes personal data you provide when you:

– apply for our services; – request marketing information/material to be sent to you; – contact us; or – make donations via our website or fundraising portals

  • Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect these personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties including service providers that we engage and publicly available sources.
  1. LEGAL BASES FOR PROCESSING

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract (Agreement) we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • Where we have received your express consent to use your personal data

Where we are relying on consent to process your personal data, you have the right to withdraw consent at any time by contacting us. 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 our services to you. We will advise you if this is the case at the time you withdraw your consent.

  1. PURPOSES FOR WHICH WE MAY USE YOUR PERSONAL DATA

We have set out below, in Table 1, a description of the ways we may use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out in the table below.

Table 1 – Purposes and Lawful grounds for processing

 

Purposes Lawful grounds for processing
Responding to your enquiry, requests and complaints Legitimate interest
Legal Obligation
Processing of Donations Legitimate interest
Consent
Legal obligations
Marketing communication Consent
Providing newsletters Consent
Communication of fundraising events and activities Legitimate interests
Conducing market research Legitimate interests
Consent

Change of purpose

We will only use your personal data 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.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis for the processing which may require new consent from you.

Please note that we may sometime need to process your personal data without your knowledge or consent, where this is required or permitted by law.

  1. THIRD PARTY LINKS

This 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 leaving our website, we encourage you to read the privacy notice of every website you visit.

  1. COOKIES

Cookies are small text files placed on your computer whenever you visit a website. They help collect standard internet log information and visitor behaviour information during your visit to the website.

We use Google Analytics cookies to analyse the use of our website. You can learn more about Google practices by visiting www.google.com/policies/privacy/partners. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Notice

  1. SHARING YOUR PERSONAL DATA

We may share your personal data with the parties listed below.

  • IT Service providers
  • Marketing/business Software providers e.g Mailchimp
  • Government Agencies or Authorities
  • Law enforcement Agencies
  • Third parties to whom we may choose to sell, transfer or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change of ownership happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to take the security of your personal data very seriously and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. INTERNATIONAL TRANSFERS

We do not typically transfer your personal data outside the European Economic Area (EEA). Should we need to transfer your data outside the EEA we will ensure that the appropriate legal safeguard is in place to allow the transfer. For example:

– We will ensure that the Country has been deemed as having an adequate provision by the European Commission (adequacy decision); or

– Where there is no adequacy decision, we may use standard contracts approved by the European Commission (Standard Contractual Clauses)

  1. DATA SECURITY

We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those volunteers, agents, contractors and other third parties who have an operational need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION

We retain your personal data for as long as necessary to fulfil the purposes we initially collected it for and for the purposes of meeting any legal, Financial or reporting requirements. Our internal data retention policy sets out the criteria we use for determining retention periods for the relevant purposes. Personal data that we no longer require are securely disposed of.

  1. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation in relation to your personal data that include:

  • Right to request access to your personal data.
  • Request correction of your personal data (rectification)
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.

See Table 2 below for an explanation of each right.

If you wish to exercise any of your rights, please contact us at privacy@africandevelopmentchoices.org or write to us at Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX.

You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

We try to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, it could take us longer than a month to respond. In such cases, we will notify you and keep you updated.

Right to be informed – You have the right to be informed about the collection and use of your personal data.
Right to access – You have a right to request a copy of personal data we hold about you – subject to certain exemptions.
Right to Rectification – Your right to have inaccurate or incomplete data about you rectified.
Right to erasure – Known as the ‘right to be forgotten’. This is your right to request the deletion or removal of your personal data. It is not an absolute right and only applies in certain circumstances.
Right to object – Object to direct marketing, to processing for the purposes of scientific/historical research and to statistics and processing based on the legitimate interests.
Right related to automated decision-making including profiling – This is to protect individuals from processing carried out solely by automated decision making that has legal or significant effect on them.
Right to restrict processing – In certain circumstances you can request for us to limit the way we use your data.
Right to data portability – Your right to receive personal data provided to ADC in a certain formator transmitted directly to a third party of your choice.

  1. FURTHER INFORMATION

We keep our privacy notice under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us at privacy@africandevelopmentchoices.org

If you have any questions about this privacy notice or our privacy practices, please contact us in any of the following ways:

  1. Email address: privacy@africandevelopmentchoices.org
  2. Postal address: African Development Choices Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX

This privacy notice was last updated in July 2020.

  1. COMPLAINTS

If you are not happy with how we handle your personal data or requests, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

You can contact the ICO:

via their website: https://ico.org.uk/ by Telephone: 0303 123 1113 or 01625 545 745

OR

In writing: Information Commissioner’s Office (ICO)

Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

15.0 GLOSSARY OF TERMS

Absolute Right – means rights that can never be interfered with in any circumstances.

Consent – of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Data Controller -are the main decision-makers – they exercise overall control over the purposes and means of the processing of personal data.

Personal Data – any information that relates to an identified or identifiable individual.

Processing -means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor -means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Third party -means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process persona