We are committed to protecting your privacy and protecting your personal data and will only use the information that we collect about you lawfully. This privacy notice is intended to give you an understanding of how and why we use the information you give us.
Stewardship is managing the giving for The Pearl Fund and has its own Privacy Notice for the processing of personal data provided when you give with Stewardship.
You may contact us at any time about your data privacy matters. If you have any questions about this privacy notice you can email us at firstname.lastname@example.org.
We may update this policy from time to time without notice to you, so please check it regularly.
How we collect information about you
We may collect information from you in the following ways when:
you visit our website;
you share your experience of the Pearl Fund;
you attend a Pearl Fund event;
you apply for a job with us or volunteer with us or provide services via an agency or provide consultancy services directly to us;
you contact us with enquiries or other correspondence (including via social media) or become involved with us in another way and indicate you would like to hear more from us.
If you interact with us in one of the ways listed above, we may collect and process personal information about you such as:
details of your visit to our website, including your IP address;
your name, address, email address, telephone number, your age or the corporate entity you represent;
information you enter onto our website or in hard copy form at an event;
records of your correspondence with us if you have contacted us;
whether you have a relationship to another supporter.
We may also collect sensitive personal information about you, such as details about a health condition or disability, where it will mean we can communicate with you appropriately in the future. We may also collect this information if you plan to attend an event.
When your political affiliation or religious beliefs are of public knowledge, we may also record that information against your profile. If they are not in the public domain, we will only do so where we have your consent or have drawn this specifically to your attention.
When you attend an event or activity, we may take photographs and videos of you. Your image may be used in print and digital formats, including print publications, websites, film, and social media. We will always inform you if photography or filming is being carried out by us at an event. Event participants have the right to decide whether their images are taken and how these may be used and stored by us.
How we use your information and on what basis
The Data Protection Act 2018 requires organisations to have a valid lawful basis in order to process personal data. Generally, the Pearl Fund will process your data on one or more of the following lawful bases:
Where the processing of your personal data is necessary for the performance of a contract or legal agreement to which you are party, or where a contract forms the basis of your interaction with the Pearl Fund;
Where you have provided your consent to us to use your personal data in a particular way. For example, in connection with your choices to receive marketing communications by email or text. We may seek your explicit consent for the processing of your data if you share sensitive personal data with us;
Where the processing is necessary for the purpose of a legitimate interest pursued by us or a third party and your privacy rights do not override the legitimate interest. Our “legitimate interests” include pursuing the objectives of the Pearl Fund through our work to support education initiatives in Africa. However, "legitimate interests" can also include your interests, such as when you have requested information from us, and those of third parties, such as our beneficiaries;
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
For example, we rely on legitimate interests for activities such as: sending marketing communications by post or telephone (unless you have told us that you would prefer not to hear from us in this way), contacting you as a representative of an organisation about a charity partnership or in order to organise an event, and analysing your interaction with us to improve our internal business processes.
Where processing is necessary to comply with a legal obligation. For example, we may rely on this legal basis for processing your personal data in relation to HMRC obligations.
Where processing is necessary in order to protect the vital interests of the data subject or of another natural person, such as in a medical emergency, for example, if someone is taken ill at one of our events.
We will process your data for one or more of the following reasons:
To maintain our relationship with you and update you on the impact of your support to us;
To provide you with the services, activities or information you have indicated you are happy to receive or which you have asked for;
To comply with applicable laws and regulations, and requests from statutory agencies;
For internal administrative purposes and to keep a record of your relationship with us;
For the purposes of internal research to improve our effectiveness;
For marketing purposes, to provide you with information about us, our fundraising campaigns, the opportunity to leave a gift in a will, our events, our services, and any other information, products, activities or services that we provide or provide access to, such as supporter updates;
To invite you to attend an event;
To manage your communication preferences with us;
To provide you with information about goods or services we feel may interest you;
To notify you about changes to our service or fundraising opportunities;
To undertake appropriate due diligence on the individuals and organisations we work with.
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 we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Where the law allows us to do so and to improve the quality and accuracy of the information you have provided to us, we regularly check the accuracy of the data we already hold about you (such as your telephone number, email address or address) against external data lists which are in the public domain (for example the Royal Mail). We may also use third parties to check this on our behalf. If we obtain updated details, we will combine this with the information we currently hold about you.
We may use unautomated profiling and screening techniques to analyse your personal information and create a profile about you, your interests and preferences from publicly available information. The types of information collected about you from the public domain will include:
a wealth band which will be an estimate of your wealth based on publicly available information;
your trusteeships and the type of charity of which you are a trustee and your company directorships;
your donation history;
your primary business organisation.
Occasionally we may use the information you provide to us to improve the accuracy and relevancy of any digital advertising you receive. This could include securely providing contact details such as your name and email address to digital advertising networks or social media companies such as Facebook, Google and Twitter. We may also use your information to enable us to display adverts to potential supporters who have similar characteristics to you, such as lookalike audiences. Information shared with third parties is always carried out in accordance with data protection laws and regulations.
You can stop your information being used for this by contacting us.
Where you have asked us not to use your information for targeted digital advertising, you may still see adverts related to the Pearl Fund. This is because certain social media sites or advertising networks may select you based on information they hold, such as your age and location, or websites you have visited, without using information that has been provided by us.
Where is your information stored?
The Pearl Fund has appropriate physical, technical, and procedural safeguards in place in relation to the storage of data.
Information about you will usually be stored in the United Kingdom or the European Economic Area (EEA). In cases where we need to store data outside the EEA, we will use reasonable endeavours to ensure the recipient of the data implements GDPR-compliant measures to protect your information.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long do we keep your data?
We will process and retain your data only for as long as is reasonable and necessary in line with our data retention policy. In determining the duration, we will follow legal and regulatory guidelines. If you withdraw your permission for us to keep your personal data, please be aware that we will inform you if we are unable to do so due to overriding legal obligations.
Who do we share your data with?
We may allow our staff, consultants and/or external providers acting on our behalf to access and use your information for the purposes for which you have provided it to us. We will only provide them with the information they need to deliver the relevant service. We will ensure your information is transferred securely and treated with the same diligence as if we were handling it directly.
We do not sell your data to third parties. In other cases, we will not share your personal data with third parties except in accordance with this privacy notice or where we have your permission.
We may disclose your information to other organisations and agencies if we are under a duty to disclose or share it to comply with any legal obligation, or to enforce or apply any agreements; or to protect the rights, property or safety of us or others.
We take your data rights seriously. The General Data Protection Regulation gives you the following rights:
You have the right to be informed about the collection and use of your data;
You can request a copy of the information that we hold about you;
If the data that we hold about you is inaccurate or incomplete, you can ask to have it corrected;
You can ask for the data we hold about you to be erased from our records;
You can ask us to restrict processing of your data where certain conditions apply;
You can ask to have the data we hold about you transferred to another organisation;
You can object to certain types of processing such as direct marketing.
We do not carry out automated decision making and profiling.
You can exercise your data protection rights in the following way:
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. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Instructions for unsubscribing from emails are included in each email we send.
If you are unhappy with the way we have processed your personal data, you should contact the Information Commissioner’s Office (https://ico.org.uk). You are entitled to make a complaint to the Information Commissioner’s Office without first referring your complaint to us.
What are cookies?
Necessary cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. These cookies do not store any personally identifiable information.
Analytical cookies: These cookies allow us to measure visits and traffic sources so we can improve the performance of our website.
Marketing cookies: These cookies may be set through our site by our advertising partners to build a profile of your interests and show you relevant advertisements on other sites.
We respect your privacy and you can choose not to allow some types of cookies.
How to manage your cookie settings
Many web browsers such as Internet Explorer, Google Chrome or Safari, will allow some control over cookies through their settings. To manage your cookie settings, please refer to your browser software. For more information about cookies and how to delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Please note, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all our parts of our website.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Service providers of IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.