We respect the privacy of every person who visits or registers with https://www.bestforbritain.org, any and all subdomains, and any and all Best For Britain controlled domains such as Hey-MP.uk (the “Site”) and uses the Site’s functionality to stay abreast of campaign developments as well as contact politicians and influencers as part of those campaigns (the “Functionality”).
1. PURPOSE OF THIS POLICY
Nothwithstanding the above, this policy does not apply to personal information collected during your communications with third parties for which Best For Britain has no control and/or knowledge.
2. WHO ARE WE AND WHAT DO WE DO?
The Site is operated by UK-EU Open Policy Limited (“we” “us” or “our”) whose principal activities include managing the Best for Britain political campaign. For more information see below.
UK-EU Open Policy Limited is the data controller responsible for your personal information. UK-EU Open Policy Limited 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 and whose principal address is 11 Manchester Square, London W1U 3PW and whose registered address is International House, 24 Holborn Viaduct, London, EC1A 2BN.
3. HOW TO CONTACT US?
- sending an e-mail to firstname.lastname@example.org;
- or writing to us at The Data Protection Officer, Best for Britain, International House, 24 Holborn Viaduct, London, EC1A 2BN.
4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
Personal information is collected from you in the following ways:
1. Information you voluntarily provide to us. For more information see below.
We collect and maintain personal information that you voluntarily submit to us during your use of the Site (e.g. when registering with us or when you correspond with us). or if you sign up with us at an offline event (e.g. provided 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).
In particular we collect:
- demographic information (such as post code);
- e-mail address;
- phone number;
- social media log in details that you provide to us;
- bank account details to allow our payment processors to process donations, details about payments to and from you and other details of products and services you have purchased from us; and
- other information that you provide to us (which may include information provided in any questions, comments or feedback you leave on the site).
Other than the information which is definitely required to set you up as a user of the Site you have the flexibility to provide us with as little or as much of this requested information as you like. However, the more information you provide, the more you will get out of the Site.
If you contact us, we may collect additional personal information from you such as your opinion on our service.
We do not collect "special categories of personal data" about our supporters (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), unless you expressly provide it to us.
All special categories of personal data are stored on an access-controlled secure database. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you request to see it.
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 a product or service you have with us but we will notify you if this is the case at the time.
The Hey-MP.uk tool allows you to easily contact your member of Parliament and in order to facilitate this we collect your email address, postcode, the date and time you used the tool, and your IP address. We do not collect and/or save your messages on email or otherwise to members of Parliament.
2. Information we collect through your use of the Site. For more information see below.
- 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.
3. Information we collect from third parties. For more information see below.
We may also combine personal information that we collect through your use of the Site 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 obtained from a public record (e.g. the electoral roll).
Independent third parties will pass your data to Best For Britain where you have indicated that you wish to support Best For Britain and have given your consent to Best For Britain processing your personal data or it is a necessary part of completing a contract with you.
We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn among others, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
5. 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 Site, improve our campaigns and develop new campaigns and areas of interest, (iii) carry out requests made by you on the Site, (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 Site, (viii) provide support and security for the Site and the Functionality, and (ix) use as such information as otherwise required or permitted by law. In particular, we use your personal information for the following purposes:
In particular, we use your personal information for the following purposes:
Provision of the Site and the Functionality. For more information see below.
We use this information to communicate with you, to carry out digital campaigning, to fulfil actions you request on the Site, such as requests for support, and to track the transaction/requests that are performed. This activity may include conducting digital campaigning by emailing politicians and other decision-makers on important issues when you request us to do so using the Functionality (and we will share your information with these third parties for this purpose).
What is our legal basis?
We will obtain your explicit consent to use your personal information for the provision of Site and the Functionality.
Information Requests and Feedback. For more information see below.
Our Site contains various user interfaces to allow visitors to request more information about our services, to use the functionalities of the site, or to provide us with feedback about them.
Contact information may be requested in each case, along with information about your computing environment and/or industry, and details of your request or reported feedback. This information is used in order to allow us to respond to your requests, to assure that our software and services work correctly.
What is our legal basis?
We will obtain your explicit consent to use your personal information for the provision of Site and the Functionality. It is also in our legitimate business interests to respond to any requests you make to us or use the information you provide to us in your feedback in order to improve our products and services.
Surveys/Campaign Questionnaires. For more information see below.
It is likely that surveys and/or campaign questionnaires will appear on the Site 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.
What is our legal basis?
By voluntarily participating in our surveys and or questionnaires we rely on your consent to use the personal information we collect as part of such survey. It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service, campaign information and feedback we can to you.
Profiling. For more information see below.
We use your information for user profiling to ensure that our campaign and any messages we send you are as effective as possible.
What is our legal basis?
We will obtain your explicit consent to use your personal information for the provision of Site and the Functionality. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service, campaign information and feedback we can to you.
Site administration. For more information see below.
We use your personal information to:
- develop and improve the Site and Functionality;
- send you administrative e-mails about the Site; and
- contact you to answer any queries you may have.
What is our legal basis?
We will obtain your explicit consent to use your personal information for the provision of Site and Functionality. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service, campaign information and feedback we can to you.
User Data Analysis. For more information see below.
Our web pages and e-mails contain "web beacons"; or “pixel tags.” Web beacons and pixel 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 Site (and use this information to improve the Site). This allows us to learn what pages are most attractive to our visitors, which parts of our Site is 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 Site is being used. Once you click on an e-mail that contains a web beacon, your contact information is subsequently be cross-referenced to the source e-mail and the relevant web beacon or pixel tag information.
In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymous form, we will obtain your explicit consent to use your personal information for the provision of Site and the Functionality.
Internal record keeping and legal compliance. For more information see below.
What is our legal basis?
Campaign updates, promotional and marketing messages and ongoing communication from us. For more information see below.
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 list 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.
What is our legal basis?
We will obtain your explicit consent before sending you such campaign updates, promotional and marketing messages and other communications.
Sharing information with third parties. For more information see below.
We may share your personal information collected on the Site with third parties as appropriate to (i) carry out the activity or request made by you on the Site, (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 Site, or (vi) as otherwise required or permitted by law.
The types of third party we share your personal information with are platform providers which allow us to deliver the Functionality on the Site and to host and store your personal data.
We may need to 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.
We may also 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 and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.
In addition, 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 social media site.
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.
What is our legal basis?
Where we share your sensitive personal information, we shall be relying on your consent to do so. It is also in our legitimate interest to share your personal information in such a way to ensure that we provide the very best service, campaign information and feedback we can to you.
Sharing information with professional advisers; potential purchasers. For more information see below.
We may share your personal information with professional advisers or regulatory authorities:
(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.
What is our legal basis?
Where we share your sensitive personal information, we shall be relying on your consent to do so. It is also in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions.
6. HOW DO WE OBTAIN YOUR CONSENT?
Where our use of your personal information requires your consent, you can provide such consent:
- at the time we collect your personal information following the instructions provided; or
8. THIRD PARTY LINKS AND SERVICES
Your browsing and interaction on any other website, 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.
9. TRANSFERS OUTSIDE THE EEA
Your data is only processed outside the EU where Best For Britain has verified that appropriate standards and safeguards are in place. Best For Britain uses NationBuilder, DoGooder, Google Cloud/Drive, as service providers that operate outside of the EU but they 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.
10. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for our purposes.
In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
If your information is only useful for a short period e.g. for specific campaigns we will delete it.
11. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
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. For more information see below.
We have implemented information security policies, 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 Site.
12. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
You have the following rights in relation to the personal information we hold about you:
Your right of access. For more information see below.
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. For more information see below.
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. For more information see below.
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. For more information see below.
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. For more information see below.
With effect from 25 May 2018, 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. For more information see below.
You can ask us to stop processing your personal information, and we will do so, if we’re: o 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. For more information see below.
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. For more information see below.
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.
- Your right to unsubscribe here https://www.bestforbritain.org/unsubscribe
Your right to lodge a complaint with the supervisory authority. For more information see below.
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.