About us and your privacy
SkyWay Charity (also referred to as “SkyWay”, “we”, “us” and our”), a charity registered in England and Wales with charity registration number 1093239, is committed to protecting and respecting the personal data that we collect in the course of operating our charity. As used in this notice, “personal data” means any information relating to an identified or identifiable natural person.
For the purposes of applicable UK and EU data protection laws, this privacy notice describes how and why we collect, use, share or otherwise process personal data as a data controller in the course of operating our charity.
This privacy notice applies to our processing of all personal data that you provide to us, except where we have provided a more specific privacy notice to you to cover the processing of your personal data (for example, this privacy notice does not cover our processing of personal data relating to SkyWay’s employees or our processing of audio-visual personal data to raise awareness about the work that we do). It also sets out how you can instruct us if you prefer to limit the use of your personal data and the procedures that we have in place to safeguard your privacy.
The types of data we collect
We may collect personal data from you when you:
- visit and browse our website;
- fill out web forms;
- contact us with enquiries through telephone, our website, over email or post, or in person;
- sign up to our newsletter;
- support us through a donation;
- raise funds for us;
- register to participate in one of our events or workshops;
- submit a request, query, a complaint to us or when you report a problem with our services or campaigns;
- agree to complete our surveys that we use for research purposes;
- interact with us on our social media pages on Facebook, Instagram, Twitter, LinkedIn and YouTube;
- volunteer with us;
- apply for a job with us; and
- provide services directly to us
We also collect personal data from third parties (such as referrers) who have your consent to pass your details on to us.
The types of personal data that we collect will depend upon how you interact with us and are described below. For example, if you are simply signing up to receive our newsletter we may only collect your name and email address. We do not, apart from in the limited circumstances described below, collect “special categories” of personal data, such as health information and ethnicity.
Depending on the context of your interactions with us, the personal data that we may collect from you include some or all of the following information:
- Contact identifiers, such as your name, personal or business telephone number, postal and/or email address, user account name and social media identity;
- Demographic information, such as your age and gender, and we may collect information regarding your ethnic background and household size (e.g., so that we can perform impact studies);
- Health information, such as information about your health or medical conditions, medication and emergency contact or GP (e.g., if you are taking part in or attending a workshop or event, for health and safety purposes);
- Information relating to your child, including their name, age, gender, ethnic background, living circumstances and child safeguarding concerns;
- Bank account information (e.g., of suppliers); and
- Details of your visit to our website, including your IP address.
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 or information about your health or genetic or biometric data), other than health information and ethnicity, and then only when we have a clear reason to do so, such as where we need information about your health so that you can participate safely in activities and workshops.
Why we use your personal data
We may use your personal data for one or more of the following purposes, and in doing so will rely on the applicable legal ground to process your personal data:
|To provide you with the information, service, activity, event or workshop that you have requested or are taking part in||● (Pre-)Contractual necessity
● Legitimate interests
|To keep a record of your relationship with us, and to respond to or fulfil any requests, complaints or queries you make to us||● Legitimate interests
● (Pre-)Contractual necessity
● Compliance with a legal obligation to which SkyWay is subject
|To apply for funding or to meet our obligations under funding agreements||● Legitimate interests
● (Pre-)Contractual necessity
|To maintain our list of donors and event contacts||● Legitimate interests|
|To send you newsletters, marketing communications and other information or materials that may interest you, including information about our work, activities and campaigns and events, and to monitor the impact of our marketing campaigns||● Legitimate interests or
|To process volunteer or job applicant information||● (Pre-)Contractual necessity|
|To provide evidence of the effectiveness of our work||● Legitimate interests|
|To ensure the safety and wellbeing of the people that we work with||● Compliance with a legal obligation to which SkyWay is subject
● Vital interests
|To manage your communication preferences with us generally, including to activate or deactivate accounts||● Legitimate interests or
|To comply with any of the requests specified in section 10 (Your Data Protection Rights) below||● Compliance with a legal obligation to which SkyWay is subject|
|To comply with our legal and regulatory obligations, including fraud prevention and detection and money laundering checks||● Compliance with a legal obligation to which SkyWay is subject|
|To obtain legal or professional advice or services in connection with the operation of our charity||● Legitimate interests
● (Pre-)Contractual necessity
● Compliance with a legal obligation to which SkyWay is subject
When we process “special categories” of personal data, i.e., your health information and ethnic background, we require an additional justification to do so under UK and EU data protection laws, which will be either your explicit consent or another legal justification that is available to us (for example, where the processing is necessary for reasons of substantial public interest, your vital interests or for statistical purposes).
We may also anonymise your personal data and use it for the purpose of monitoring the usage of our websites or our services, to improve our services and to compile statistics, and may share such anonymised information with third parties. This information and statistics will not include information that can be used to identify you.
Marketing and fundraising communications
It is your choice as to whether you want to receive marketing information from SkyWay, including information about our work, how we raise funds and the ways you can get involved. You can highlight your preferences on the relevant form, by telling us in person, or by contacting us separately.
We will not send you marketing emails or text messages without first receiving specific consent from you, unless we have an existing relationship with you and wish to contact you about the services, events and publications similar to those which we provide you, or in which you may be interested. It is always open to you to change your marketing preferences and you may opt-out from receiving our marketing emails and texts at any time by clicking on the “unsubscribe” link at the end of our marketing emails or by sending us an “opt-out” text message.
Security and retention of your personal data
We have put in place appropriate technical and organisational security policies and procedures to protect your personal data.
All information collected by us is stored securely in our database, and we use two-factor authentication where appropriate.
When we collect your personal data we use strict procedures and security features to prevent unauthorised access, and limit access to your personal data to those SkyWay employees, agents, contractors and other third parties who have a business need to know, and are subject to a duty of confidentiality. We train our staff and volunteers in handling your personal data in accordance with this privacy notice and applicable data protection legislation.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable data protection authority of a personal data breach where we are legally required to do so.
Sharing your personal data
Like most charities, SkyWay uses volunteers to help us achieve our charitable objects and fundraising efforts. Our volunteers are all properly trained in data protection matters and are aware of the terms of this privacy notice. If you do have any concerns in that respect please feel free to contact SkyWay’s data protection officer whose details are set out below.
We do not sell your personal data to any third parties, but we may share some of your personal data with our trusted service providers and suppliers who help us carry out our business, including data hosting providers. They cannot use your data for any other purpose than the relevant purpose listed above in this privacy notice, and we only use those service providers and suppliers who undertake to protect your details and your privacy with the same degree of care as we do.
We may also share your personal data with the following third parties:
- Our trusted partners, including other charities, social enterprises and organisations who help support or promote SkyWay’s work;
- Our auditors and other professional or legal advisers;
- Companies, organisations, other legal entities and regulatory or governmental bodies for the purposes of fraud detection or protection;
- Statutory agencies where there is a safeguarding concern, and organisations who regulate what we do (such as government bodies, law enforcement agencies or the Information Commissioner’s Office); and
- to the new owner(s) of our business and their professional and legal advisors, if we are the subject of an acquisition, reorganisation or other business transaction.
Transfers of your personal data
To the extent that SkyWay transfers your personal data outside of the UK or the European Economic Area (“EEA”), SkyWay will only do so in a way which complies with the requirements of applicable data protection legislation, which may include using the model contractual clauses.
Social media and links to other sites
Our website and our materials may include links to other sites and other organisations not owned or managed by us. We are not responsible for the content and privacy of information collected by any entity not managed by us.
If you post, or send any content that we believe to be inappropriate, offensive, or in breach of any laws, such as defamatory content, on our forms, or on our social media pages, we may use your personal data in order to file reports with relevant third parties such as your internet provider or law enforcement agencies.
A cookie is a small piece of information that is placed (or “set”) on your device or computer when you visit a website and that can be used to identify the user or device and to collect data. For more information on cookies, please see www.aboutcookies.org.
We need your consent to set any cookies that are not essential to enable you to move around our website and use its features. You have the opportunity when you first visit SkyWay’s website to accept or decline cookies, and you can also change your cookie settings (including disabling cookies) at any time by adjusting your browser settings.
We set “performance” cookies, which monitor visitor behaviour on our website, to help us improve our website, and “analytics” cookies which help us understand and analyse the impact of our marketing campaigns.
The following cookies are set by SkyWay’s website:
|Google Analytics||SIDCC, _Secure-3PSIDCC, _Secure-3PAPISID, _Secure-APISID, SAPISID, SSID, HSID, _Secure-3PSID, SID, _Secure-SSID, _Secure-HSID, APISID, _ga, CONSENT, ANID, OTZ, 1P_JAR, FBP, _gid, NID, DSID, IDE||We use these performance cookies to collect information about how visitors use our website, which we use to help us improve the website.|
|wd, dpr, fr, sb, _abck, _fbp, datr||We use Facebook pixel, which is an analytics tool that allows us to measure the effectiveness of our campaigning and promotional material by understanding the actions people take on our website. We use the pixel to make sure we’re reaching the right people, understand the results of our campaigns, and measure what happens when people look at them.|
The following cookies are set by third-party websites:
|YouTube||SIDCC, LOGIN_INFO, YSC, VISITOR_INFO1_LIVE, _Secure-3PAPISID, SSID, _Secure-SSID, Secure-HSID, SAPISID, APISID, _Secure-3PSID, PREF, HSID, _Secure-APISID, SID||We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. Read more at YouTube’s embedding videos information page.|
How long do we keep your personal data
We keep records of your personal data only for as long as is necessary: (i) for the performance of our contract with you (i.e. our user terms applicable or our website terms); (ii) to achieve the purpose(s) for which such personal data was provided to us as set out above in this privacy notice; or (iii) for legal reasons, or to comply with any legal requirements such as tax and accounting rules. Where your information is no longer required, we will ensure it is disposed of in a secure manner. For further information about how long we will keep your personal data, please contact email@example.com
Your data protection rights
Access: you are entitled to be provided with a copy of the personal data we hold about you free of charge, however, we may charge a reasonable fee, if we think that your request is excessive, to help us cover the costs of locating the personal data you have requested.
Deletion: you have the right to ask us to delete any personal data we hold about you.
Rectification: you are entitled to have any inaccuracies in the personal data we hold about you corrected.
Withdraw consent: if you previously gave us your consent to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
Information: you have the right to be informed of the use to which your personal data is put.
Restrictions on use: you have the right to request us to restrict the processing of your personal data if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your personal data to establish or defend a legal claim; or (iv) you object to the processing of your personal data and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
Object: you have the right to object to our processing your personal data: (i) for our legitimate interests or the performance of a task in the public interest; (ii) for direct marketing; (ii) for scientific/historical research and statistical purposes.
Portability: if you wish to transfer your personal data to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send the data directly to another organisation if this is technically feasible.
If you wish to exercise any of your rights, please contact our data protection officer whose details are set out below. Please note that we may need to request specific information from you to help us confirm your identity. 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.
SkyWay’s data protection officer is Natalie Roast, CEO. If you have any questions regarding our processing of your personal data, or requests relating to the exercise of your data privacy rights under applicable law, please contact her at firstname.lastname@example.org
If you would like to let us know about something we have done, or failed to do, whether positive or negative, regarding your personal data please also let us know. Your comments enable us as an organisation to learn and continuously improve our services.
If you think there is a problem with the way we are handling your personal data, you have the right to complain to the Information Commissioner’s Office. You can also contact the Information Commissioner’s Office if you have a complaint that we cannot resolve:
Updates to your personal data
If your personal details change, please help us to keep your information up to date by notifying us at email@example.com
Adopted in March 2015
The policy is to be reviewed in February 2022
The designated person is SM