WIN Policy Privacy Notice for Website

Revision: 1.1
Review Date: 11 April 2025
Review Period: 1 year
Next Review: 11 April 2026
Document type: Policy

1.0 Policy Statement

1.1. Introduction

World in Need International (We) respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how to look after your personal data when you visit our website (regardless of where you visit it from). We'll also tell you about your privacy rights and how the data protection law protects you.

1.2. Purpose

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you use the link to email us, sign up for our newsletter or navigate through the site.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1.3. Data Controller

World in Need International is the controller and responsible for this website and your personal data (collectively referred to as "we", "us" or "our" in this privacy notice). Our contact details are info@worldinneed.org.uk. The person responsible for our personal data compliance is the CEO.

1.4. Third-party links outside of your control

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

1.5. The Personal Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

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

• Identity Data includes first name, surname, username, title, date of birth, gender.
• Contact Data includes telephone number/s, email address, billing address, delivery address.
• Financial Data includes bank account number, sort code.
• Transaction Data includes details about payments to and from you, details of products and services you have purchased from us.
• Technical Data includes IP address, your login data, browser type and version, location, operating system, other technology on the devices you use to access this website
• Profile Data includes username and password, purchases or orders made by you.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences.

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

1.6. If you fail to provide personal data

Where we need to collect your 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

1.7. How We Collect Your Personal Data

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

1. Directly. You may supply us with your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
2. Apply for membership, products or services;
3. Create an account on our website;
4. Subscribe to our service or publications;
5. Request marketing to be sent to you.
6. 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 this personal data by using cookies and other similar technologies. Please see our cookie policy for further details. Third parties or publicly available sources.

1.8. Third parties or publicly available sources

We may receive personal data about you from various third parties (and public sources) as set out below:

1. Analytics providers (such as Google, based outside the EU);
2. Search information providers (such as Google or Bing, based inside OR outside the EU).Contact, Financial and Transaction Data from providers of technical, payment and delivery services (such as Go Cardless based (inside OR outside) the EU). Identity and Contact Data from publicly available sources (such as Companies House and the Electoral Register based inside the EU).
3. Social Media sites (such as Facebook, X, Linkedin, based inside OR outside the EU). Contact, Financial and Transaction Data from providers of technical, payment and delivery services (such as paypal based (inside OR outside) the EU). Identity and Contact Data from publicly available sources (such as Companies House and the Electoral Register based inside the EU).

1.9. How we Use Your Personal Data

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:

1. Performance of Contract: this 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, such as your Membership Agreement with us.
2. Legitimate Interest: this means the interest of our business in conducting and managing our business to enable us to give you the best service/support/product and the 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).
3. Comply with a legal or regulatory obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

1.10. Purposes For Which We Will Use Your Personal Data

We have set out below, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose / Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a member	(a) Identity (b) Contact	Performance of a contract with you: Membership Agreement
To process your membership, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms of privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how members and website visitors use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restricting exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how members and website visitors use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, support/products/services, marketing, member relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage	Necessary for our legitimate interests (to develop our range of support/products/services and grow our business)

1.11. Newsletters, Bulletins and Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. One of the member benefits is regular communication from us to keep you up to date with relevant legislation or statutory changes that may affect your charity, therefore, we will use the contact details you provide to communicate with you and always offer you a clear option and method to unsubscribe to these communications.

We do not share or sell your personal data to third parties for marketing purposes.

1.12. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any update bulletin or email sent to you.

1.13. Cookies

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 Policy.

1.14. 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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the purpose and 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.

1.15. Who We Share Your Personal Data With

We may have to share your personal data with the parties set out below for the purposes set out in the table above:

• Providers based in the UK who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
• Carefully selected external consultants who support [insert organisation name] in delivering their service to members.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, 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 respect the security of your personal data 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

1.16. International Transfers

In compliance with the conditions for transfer set out in the GDPR (Article 45, Recitals 103- 107) and the Data Protection Act 2018, we may use third parties as Data Processors to provide elements of the Services we supply to you. The third parties may if necessitated transfer personal Data outside of the EU; (i) only if contracts are in place between the us and the third parties; (ii) the third parties only process Data for completing the Services as instructed by us; (iii) third parties may not share personal information with any organisation apart from us.

1.17. Data Security

We have put in place appropriate security 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 employees, agents, contractors and other third parties who have a business 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.

1.18. Data Retention

1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
3. By law we have to keep basic information about our members (including Contact, Identity, Financial and Transaction Data) for six years after they cease being members for tax purposes.
4. In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
5. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

1.19. Your Legal Rights

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• Be informed that your personal information is being collected – at the point of collection – and the purposes for which it is being processed, retention periods and who it will be shared with;
• Access personal data held and processed by us;
• Rectification of any personal data that is inaccurate or incomplete;
• Erasure, or to 'be forgotten' if your data is no longer necessary for the purpose for which it was collected and Consent is the lawful basis for processing;
• Request that processing is restricted although we may still store their personal data; this is an alternative to requesting erasure of your data and the restriction is likely to be for a fixed period
• Data portability if data is processed by automated means, which means to receive your data, or some of your data, in a format that can be easily used by another person (including the data subject themselves) or organisation;
• Object to processing in certain circumstances, including preventing the use of their data for direct marketing;
• Request human intervention if automated decision-making or profiling is used.

If you wish to exercise any of the rights set out above, please contact the CEO No fee required – with some exceptions. 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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request.

1.20. What we may need from you

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.

1.21. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

1.22. Changes To This Notice and Your Duty to Inform Us of Changes

This Privacy Notice is reviewed periodically in line with our policy review schedule. Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

1.23. Queries, Requests Or Concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data officer, the CEO.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK