Privacy Policy

1. Introduction

UK-EU Open Policy Limited – which is primarily known as Best For Britain - (“Best For Britain”, “we”, “us” or “our”) respects the privacy of every person who visits or registers with Bestforbritain.org as well as any and all subdomains, and any and all Best For Britain controlled domains using the related names (the “Sites”) or who uses the services that we make available from the Sites to run our campaigns (the “Services”).

Purpose of this Policy

This Privacy Policy (“Privacy Policy”) explains our approach to any personal data we may collect about you when you interact with us or which we have obtained about you from a third party, the purposes for and basis upon which we process your personal data.  It also sets out your rights in respect of our processing of your personal data, how we’ll store and handle that data, and keep it safe. We may need to update this Privacy Policy from time to time and will notify you of any material changes by sending you an email or displaying a notification on our Sites, so please check them regularly.  

2. Best for Britain

Who are we and what do we do?

The Sites and our Services are operated by UK-EU Open Policy Limited. We operate the Sites under the following campaign names: 

  • Best For Britain.org

  • StartVoting.org

  •  GetVoting.org

  • Hey-MP.uk

The personal data required to use the Services that we provide through the Sites varies per domain, and we provide further information on this in the section When do we collect your personal information and how do we use it?

UK-EU Open Policy Limited is the data controller responsible for your personal data and is registered at the UK Information Commissioner’s Office with registration number: ZA248018.

UK-EU Open Policy Limited is an English company with registered company number: 10436078, whose registered address is International House, 24 Holborn Viaduct, London, EC1A 2BN.

How to contact us?

If you have any questions about this Privacy Policy or wish to exercise your rights please contact us by:

  • sending an e-mail to Compliance@bestforbritain.org
  • writing to us at The Compliance Team, Best for Britain, International House, 24 Holborn Viaduct, London, EC1A 2BN

3. The legal bases we rely on

There are number of bases in law that we rely on in collecting and processing your personal information.  These are:

  • Consent – when we collect your data with your consent.  E.g. when you subscribe to our campaign emails or accept our cookies to help ensure that the advertisements that you see online are in line with your interests.
  • Legitimate interest – when we use your data in a way which might be reasonably expected given the nature of our campaign and which does not materially impact your rights, freedoms or interests. E.g. when you are identified to us as a potential donor.
  • Legal compliance – when the law requires it, we may need to collect and process your data.
  • Contractual compliance – we may use your data to comply with our contractual obligations.  E.g. when you order merchandise we will pass your address to our delivery provider. 

4. When do we collect your personal information and how do we use it?

Personal information is collected from you in the following ways:

Information you voluntarily provide to us

  • During your use of the Sites or our Services (e.g. when joining us or when you correspond with us), or if you sign up with us at an offline event (e.g. when you provide us with your details in the process of signing a petition or filling in a request for further information about the Best For Britain campaign).
  • If you contact us, we may collect additional personal information from you such as your opinion on our campaign.
  • If you use our Sites to communicate with a Member of Parliament or political figure we will use your personal information such as postcode and contact details when processing your communication.
  • If you use our Sites to facilitate your application to register to vote or for tactical voting information, we will use the personal information necessary for the voter registration process and your postcode when processing your application to digitise it or present our view of tactical voting options.
  • We may process your personal data where it is necessary for the performance of a contract with you, such as for completion of transactions you have entered into with Best For Britain or the activity or online content you have signed up for.
  • 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, where you make online purchases or donations). In this case, we may have to cancel your subscription to our campaign emails or other services you request from us but we will notify you if this is the case at the time.

Information we collect through your use of the Sites

  • Through our use of cookies, log files and other technologies, we collect personal information and other information regarding your mobile device or the computer hardware and software used to access the Sites. This includes the following:
    • IP address of device(s) used;
    • browser type;
    • operating system and device type;
    • approximate location (e.g. London);
    • access times and dates; and
    • referring website addresses.
  • We also collect personal information regarding your use of and activity on the Sites. This personal information allows us to deliver more helpful information, services and tools. Please see our Cookie Policy for further information.

Information we collect from third parties. We may also combine personal information that we collect through your use of the Sites with personal information that: a) you have provided to third parties and in respect of which you have given the third party permission to share with us (e.g. our third party crowd funding platforms); and/or b) we have lawfully obtained from a public record (e.g. the electoral roll).

Independent third parties will pass your personal data to Best For Britain where you have explicitly expressed  your wish to support Best For Britain and have given your consent to Best For Britain for processing your personal data or it is required for the performance of a contract with you.

We may also obtain your personal data through your use of social media such as Facebook, Twitter or Instagram, depending on your settings and the privacy policies of those social media services, or where you share our content through such social media platforms.   

To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.  We also provide information on how to opt out of cookies from social media in our Cookie Policy

How do we use your personal information?

Our primary goal in collecting personal information from you is to (i) verify your identity, (ii) help us improve the Sites, (iii) improve our campaign Services and develop new campaigns and areas of interest, (iii) carry out requests made by you on the Sites, (iv) investigate or settle inquiries or disputes, (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator, (vi) enforce our agreements with you such as our website terms and conditions of use, (vii) protect the rights, property or safety of us or third parties, including other users of the Sites, (viii) provide support and security for the Sites and their functionalities, and (ix) use as such information as otherwise required or permitted by law. 

In particular, we use your personal information on our Sites: bestforbritain.org and Hey-MP.uk for the following purposes:

Purpose

Legal basis

Provision of the Sites and their functionalities

To communicate with you, to carry out digital campaigning, to fulfil actions you request on the Sites, such as requests for support, and to track the transaction/requests that are performed. This activity may include conducting digital campaigning through petitions or by emailing politicians and other decision-makers on important issues when you request us to do so using the functionalities (and we will share your information with these third parties for this purpose).

Consent

To send campaign updates, promotional and marketing messages and ongoing communication from us

If you have consented to us doing so we will add you to our mailing list for purposes of campaign updates, promotional and marketing messages and other communications. These mailing lists are used to provide you with further information about Best For Britain if you want it. We will communicate with you about the campaign and associated causes of Best For Britain and respond to any correspondence or feedback you send us.

Consent 

Information Requests and Feedback.  When you request more information about our services, to use the functionalities of the Sites, or to provide us with feedback about them.

Consent 

Surveys/Campaign Questionnaires

It is likely that surveys and/or campaign questionnaires will appear on the Sites or be sent to you via e-mail, and in such case, where you volunteer to participate, we collect personal information from you as part of the survey and or questionnaire. This information will be used to administer the survey, to analyse its results and for other specific purposes, which are disclosed at the time of collection. Survey responses will be aggregated and depersonalised before survey results are shared with any third parties.

Consent 








Profiling

We use your information for user profiling to ensure that our campaign and any messages we send you are as effective as possible.

Legitimate interest

Site administration

We use your personal information to:

  • develop and improve the Sites and Functionalities;
  • send you administrative e-mails about the Sites; and
  • contact you to answer any queries you may have.

Legitimate interest

User Data Analysis

Our web pages and e-mails contain “cookies”, “web beacons”; or “pixel tags”, (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites (and use this information to improve the Sites). This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of information our registered users like to see. Some of the web beacons that are placed on our Sites are used only by us, and other web beacons are used by our service providers on our behalf to analyse how our Sites are being used. Once you click on an e-mail that contains a web beacon, your contact information will subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to some of our Sites. We track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Legitimate interest

To process donations from subscribers 

Contract performance

Internal record keeping and legal compliance

We use your personal information for internal record keeping purposes and to check you comply with the Sites and Websites Terms of Use.

Legal compliance

To fundraise from prospective donors, donors and past donors 

We use personal information provided to us by third parties to contact prospective donors, donors and past donors and invite them to events and to support the campaign. 

Legitimate interest

Sharing information with third parties who are service providers

We will share your personal information with other related companies for purposes that are consistent with this privacy policy. Data collected online about you is combined with information that you provide when you register to use the Sites.

We may share your personal information collected on the Sites with third parties as appropriate to (i) carry out the activity or request made by you on the Sites, (ii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator, (iii) enforce our agreements with you, (iv) protect the rights, property or safety of us or third parties, including other users of the Sites, (v) perform investigative security analysis on the Sites, or (vi) as otherwise required or permitted by law.

We may share your personal data with service providers who help us to deliver our projects, fundraising activities and appeals, for instance through handling responses to our emergency appeals. These "data processors" will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing data protection clauses that protect your personal data. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.

Consent

Legitimate interest

Sharing information with professional advisers; potential purchasers

We may share your personal information with professional advisers or regulatory authorities:

(i) to enable them to process your personal information on our behalf in a manner consistent with this privacy policy;
(ii) to comply with our legal obligations;
(iii) to enforce our legal rights; or
(iv) protect rights of third parties.

Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Legitimate interest

Compliance with laws

Online personalised advertising and social media insight and remarketing

We use a combination of the information that we observe about you from your interactions with our Sites, and our email communications to you (see the User Data Analysis section above for more details) to provide you with personalised online advertising on social media platforms such as Facebook or Twitter where you are a registered user of such services.

In particular, we will use your email address and phone number to match to your account on Facebook or other social media sites in order to show you Best For Britain content while using these services. We only do this where you have opted in to marketing emails or phone calls. We keep your data secure by encrypting it and no data we hold about you is retained by the third party.


We may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in Best For Britain, and we may then show them Best For Britain content. No data we hold about you is retained by the third party.

There are two ways to prevent this use of your data, you can either update your preferences at Best For Britain by opting out of the relevant channel of communication or you can do this via the relevant social media site. We provide information on how to opt out of cookies from social media in our Cookie Policy

Updating your preferences with Best For Britain will not guarantee that you never see Best For Britain content on social media, since the social media site may select you based on other criteria and without your data having been provided by Best For Britain.

Legitimate interest

Consent

On StartVoting.org, we use your personal information for the purposes set out below.  We will not use it to send you email marketing or show you online advertisements unless you give your express consent to this. 

Purpose

Legal basis

Provision of the Site and the functionality

To enable voter registration by provision of online functionality to allow voters to register more easily. 

Legitimate interest

To send campaign updates, promotional and marketing messages and ongoing communication from us

If you have consented to us doing so we will add you to our mailing list for purposes of campaign updates, promotional and marketing messages and other communications. These mailing lists are used to provide you with further information about Best For Britain if you want it. We will communicate with you about the campaign and associated causes of Best For Britain and respond to any correspondence or feedback you send us.

Consent 

User Data Analysis

Our web pages and e-mails contain “cookies”, “web beacons”; or “pixel tags”, (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites (and use this information to improve the Sites). This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of information our registered users like to see. Some of the web beacons that are placed on our Sites are used only by us, and other web beacons are used by our service providers on our behalf to analyse how our Sites are being used. Once you click on an e-mail that contains a web beacon, your contact information will subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to some of our Sites. We track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Legitimate interest

Surveys/Campaign Questionnaires

It is likely that surveys and/or campaign questionnaires will appear on the Sites and where you volunteer to participate, we collect personal information from you as part of the survey and or questionnaire. This information will be used to administer the survey, to analyse its results and for other specific purposes, which are disclosed at the time of collection. Survey responses will be aggregated and depersonalised before survey results are shared with any third parties.

Consent 








Site administration

We use your personal information to:

  • develop and improve the Sites and Functionalities;
  • send you administrative e-mails about the Sites; and
  • contact you to answer any queries you may have.

Legitimate interest

Online personalised advertising and social media insight and remarketing

We use a combination of the information that we observe about you from your interactions with our Sites, and our email communications to you (see the User Data Analysis section above for more details) to provide you with personalised online advertising on social media platforms such as Facebook or Twitter where you are a registered user of such services.

In particular, we will use your email address and phone number to match to your account on Facebook or other social media sites in order to show you Best For Britain content while using these services. We only do this where you have opted in to marketing emails or phone calls. We keep your data secure by encrypting it and no data we hold about you is retained by the third party.


We may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in Best For Britain, and we may then show them Best For Britain content. No data we hold about you is retained by the third party.

There are two ways to prevent this use of your data, you can either update your preferences at Best For Britain by opting out of the relevant channel of communication or you can do this via the relevant social media site. We provide information on how to opt out of cookies from social media in our Cookie Policy

Updating your preferences with Best For Britain will not guarantee that you never see Best For Britain content on social media, since the social media site may select you based on other criteria and without your data having been provided by Best For Britain.

Legitimate interest

Consent

On GetVoting.org, we use your personal information for the purposes set out below.  We will not use it to send you email marketing or show you online advertisements unless you give your express consent to this.  

Purpose

Legal basis

Provision of the Site and the functionality

To enable generation of a Best For Britain recommendation ( in supported constituencies)  for a tactical vote for the best chance of electing a pro-Europe candidate. 

Legitimate interest

To send campaign updates, promotional and marketing messages and ongoing communication from us

If you have consented to us doing so we will add you to our mailing list for purposes of campaign updates, promotional and marketing messages and other communications. These mailing lists are used to provide you with further information about Best For Britain if you want it. We will communicate with you about the campaign and associated causes of Best For Britain and respond to any correspondence or feedback you send us.

Consent 

Profiling

We use your information for user profiling to ensure that our campaign and any messages we send you are as effective as possible.

Legitimate interest

Site administration

We use your personal information to:

  • develop and improve the Sites and Functionalities;
  • send you administrative e-mails about the Sites; and
  • contact you to answer any queries you may have.

Legitimate interest

User Data Analysis

Our web pages and e-mails contain “cookies”, “web beacons”; or “pixel tags”, (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites (and use this information to improve the Sites). This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of information our registered users like to see. Some of the web beacons that are placed on our Sites are used only by us, and other web beacons are used by our service providers on our behalf to analyse how our Sites are being used. Once you click on an e-mail that contains a web beacon, your contact information will subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to some of our Sites. We track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Legitimate interest

Internal record keeping and legal compliance

We use your personal information for internal record keeping purposes and to check you comply with the Sites and Websites Terms of Use.

Legal compliance

Sharing information with third parties who are service providers

We will share your personal information with other related companies for purposes that are consistent with this privacy policy. Data collected online about you is combined with information that you provide when you register to use the Sites.

We may share your personal information collected on the Sites with third parties as appropriate to (i) carry out the activity or request made by you on the Sites, (ii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator, (iii) enforce our agreements with you, (iv) protect the rights, property or safety of us or third parties, including other users of the Sites, (v) perform investigative security analysis on the Sites, or (vi) as otherwise required or permitted by law.

We may share your personal data with service providers who help us to deliver our projects, fundraising activities and appeals, for instance through handling responses to our emergency appeals. These "data processors" will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing data protection clauses that protect your personal data. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.

Consent

Legitimate interest

Online personalised advertising and social media insight and remarketing

We use a combination of the information that we observe about you from your interactions with our Sites, and our email communications to you (see the User Data Analysis section above for more details) to provide you with personalised online advertising on social media platforms such as Facebook or Twitter where you are a registered user of such services.

In particular, we will use your email address and phone number to match to your account on Facebook or other social media sites in order to show you Best For Britain content while using these services. We only do this where you have opted in to marketing emails or phone calls. We keep your data secure by encrypting it and no data we hold about you is retained by the third party.


We may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in Best For Britain, and we may then show them Best For Britain content. No data we hold about you is retained by the third party.

There are two ways to prevent this use of your data, you can either update your preferences at Best For Britain by opting out of the relevant channel of communication or you can do this via the relevant social media site. We provide information on how to opt out of cookies from social media in our Cookie Policy

Updating your preferences with Best For Britain will not guarantee that you never see Best For Britain content on social media, since the social media site may select you based on other criteria and without your data having been provided by Best For Britain.

Legitimate interest

Consent

Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy policy or otherwise from time to time including the legal basis of such use.

5. Other sites and services

Our Sites may contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies. Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Sites and does not apply to these third party websites and third party service providers.

6. Where your personal data may be processed

Your data may only be processed outside the EEA where Best For Britain has verified that there is a lawful basis for transferring the personal data outside the EEA and appropriate standards and safeguards are in place. Best For Britain uses NationBuilder, DoGooder, Google Cloud/Drive, as service providers that operate outside of the EEA but are able to ensure that any transferred personal data remains protected and secure. You can find out more about how NationBuilder keeps data secure here, for Google Cloud here, and Dogooder here.

7. How long will we keep your personal data?

We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for the purposes for which it was collected.

In considering how long to keep it, we will take into account its relevance to our business, and our contractual, legal and regulatory obligations.

If your information is only useful for a short period e.g. for specific campaigns we will delete it subsequently.

At the end of that retention period, your data will either be deleted or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. We keep the length of time that we hold your personal data for under review.

8. Security of your personal data

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. 

We have implemented information security rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Sites and Services.

9. Your rights over your personal data 

You have the following rights in relation to the personal information we hold about you:

  • Your right of access
    If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Your right to rectification
    If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to erasure
    You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to restrict processing
    You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to data portability. 
    You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
  • Your right to object. 
    You can ask us to stop processing your personal information, and we will do so, if we’re relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
    • processing your personal information for direct marketing; or
    • processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
  • Your rights in relation to automated decision-making and profiling. 
    You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
  • Your right to withdraw consent. 
    If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

10. How can you stop the use of your data for email marketing? 

If you want to stop receiving our campaign updates by email at any time, please use the unsubscribe link here or in any marketing communication sent to you : https://www.bestforbritain.org/unsubscribe

Please note you may continue to receive communications for a short period while our systems are updated. 

11. Contacting the regulator

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

12. Changes to this Privacy Policy 

Changes to this privacy policy:

October 2019: Updated to restructure & make easier to read, expand and clarify information collected and legal bases for processing, include new sites and to give amended contact details for the Best For Britain and the Compliance team.

November 2019: Updated to include information relating to data processing by new service StartVoting.org

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