1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal
data of
our
website visitors and service users; in other words, where we determine the purposes and means of
the
processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the
provision
of
our website and services, we will ask you to consent to our use of cookies when you first visit
our
website.
1.4 In this policy, "we", "us" and "our" refer to Help Lever Limited t/a Million Pixels Charity.[ For
more
information about us, see Section 13.]
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services ("usage data"). The usage
data may
include
your IP address, geographical location, browser type and version, operating system, referral
source,
length
of visit, page views and website navigation paths, as well as information about the timing,
frequency
and
pattern of your service use. The source of the usage data is our analytics tracking system,
Google
Analytics. This usage data may be processed for the purposes of analysing the use of the website
and
services. The legal basis for this processing is consent OR our legitimate interests, namely
monitoring
and
improving our website and services.
3.3 We may process your account data ("account data"). The account data may include your name
and email
address. The source of the account data is you. The account data may be processed for the
purposes of
operating our website, providing our services, ensuring the security of our website and
services,
maintaining back-ups of our databases and communicating with you. The legal basis for this
processing is
consent OR our legitimate interests, namely the proper administration of our website and
business OR the
performance of a contract between you and us and/or taking steps, at your request, to enter into
such a
contract.
3.4 We may process your information included in your personal profile on our website ("profile
data").
The
profile data may include your name and email address. The profile data may be processed for the
purposes
of
enabling and monitoring your use of our website and services. The legal basis for this
processing is
consent
OR our legitimate interests, namely the proper administration of our website and business OR the
performance
of a contract between you and us and/or taking steps, at you request, to enter into such a
contract.
3.5 We may process your personal data that are provided in the course of the use of our services
("service
data"). The service data may include your name and email address. The source of the service data
is you.
The
service data may be processed for the purposes of operating our website, providing our services,
ensuring
the security of our website and services, maintaining back-ups of our databases and
communicating with
you.
The legal basis for this processing is consent OR our legitimate interests, namely the proper
administration
of our website and business OR the performance of a contract between you and us and/or taking
steps, at
your
request, to enter into such a contract.
3.6 We may process information that you post for publication on our website or through our
services
("publication data"). The publication data may be processed for the purposes of enabling such
publication
and administering our website and services. The legal basis for this processing is consent OR
our
legitimate
interests, namely the proper administration of our website and business OR the performance of a
contract
between you and us and/or taking steps, at your request, to enter into such a contract.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or
services
("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and
selling
relevant goods and/or services to you. The legal basis for this processing is consent.
3.8 All information relating to transactions, including purchases of goods and services, that
you enter
into
with us and/or through our website ("transaction data") are processed by our partner. Visit
https://stripe.com/privacy
3.9 We may process information that you provide to us for the purpose of subscribing to our
email
notifications and/or newsletters ("notification data"). The notification data may be processed
for the
purposes of sending you the relevant notifications and/or newsletters. The legal basis for this
processing
is consent OR the performance of a contract between you and us and/or taking steps, at your
request, to
enter into such a contract.
3.10 Please do not supply any other person's personal data to us, unless we prompt you to do
so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our
subsidiaries,
our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the
purposes,
and
on the legal bases, set out in this policy
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as
reasonably
necessary for the purposes of obtaining or maintaining insurance coverage, managing risks,
obtaining
professional advice, or the establishment, exercise or defence of legal claims, whether in court
proceedings
or in an administrative or out-of-court procedure.
4.3 Financial transactions relating to our website and services are handled by our payment
services
providers,Stripe. We will share transaction data with our payment services providers only to the
extent
necessary for the purposes of processing your payments, refunding such payments and dealing with
complaints
and queries relating to such payments and refunds. You can find information about the payment
services
providers' privacy policies and practices at https://stripe.com/privacy.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may
disclose
your
personal data where such disclosure is necessary for compliance with a legal obligation to which
we are
subject, or in order to protect your vital interests or the vital interests of another natural
person.
We
may also disclose your personal data where such disclosure is necessary for the establishment,
exercise
or
defence of legal claims, whether in court proceedings or in an administrative or out-of-court
procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal
data may be
transferred to countries outside the European Economic Area (EEA).
5.2 We have office in United Kingdom. The European Commission has made an "adequacy decision"
with
respect to
the data protection laws of each of these countries. Transfers to United Kingdom will be
protected by
appropriate safeguards, namely the use of standard data protection clauses adopted or approved
by the
European Commission.
5.3 The hosting facilities for our website are situated in France. The European Commission has
made an
"adequacy decision" with respect to the data protection laws of France. Transfers to France will
be
protected by appropriate safeguards, namely the use of standard data protection clauses adopted
or
approved
by the European Commission.
5.4 You acknowledge that personal data that you submit for publication through our website or
services
may be
available, via the internet, around the world. We cannot prevent the use (or misuse) of such
personal
data
by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to
help ensure
that
we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than
is
necessary
for that purpose or those purposes.
6.3 In some cases it is not possible for us to specify in advance the periods for which your
personal
data
will be retained.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data
where such
retention is necessary for compliance with a legal obligation to which we are subject, or in
order to
protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this
policy.
7.3 We may notify you of changes to this policy by email.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law.
Some of
the
rights are complex, and not all of the details have been included in our summaries. Accordingly,
you
should
read the relevant laws and guidance from the regulatory authorities for a full explanation of
these
rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and,
where we
do,
access to the personal data, together with certain additional information. That additional
information
includes details of the purposes of the processing, the categories of personal data concerned
and the
recipients of the personal data. Providing the rights and freedoms of others are not affected,
we will
supply to you a copy of your personal data. The first copy will be provided free of charge, but
additional
copies may be subject to a reasonable fee. You can request access to your personal data by
emailing us
on
dpo@millonfornhs.com.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into
account
the
purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue
delay.
Those
circumstances include: the personal data are no longer necessary in relation to the purposes for
which
they
were collected or otherwise processed; you withdraw consent to consent-based processing; you
object to
the
processing under certain rules of applicable data protection law; the processing is for direct
marketing
purposes; and the personal data have been unlawfully processed. However, there are exclusions of
the
right
to erasure. The general exclusions include where processing is necessary: for exercising the
right of
freedom of expression and information; for compliance with a legal obligation; or for the
establishment,
exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data.
Those
circumstances are: you contest the accuracy of the personal data; processing is unlawful but you
oppose
erasure; we no longer need the personal data for the purposes of our processing, but you require
personal
data for the establishment, exercise or defence of legal claims; and you have objected to
processing,
pending the verification of that objection. Where processing has been restricted on this basis,
we may
continue to store your personal data. However, we will only otherwise process it: with your
consent; for
the
establishment, exercise or defence of legal claims; for the protection of the rights of another
natural
or
legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to
your
particular situation, but only to the extent that the legal basis for the processing is that the
processing
is necessary for: the performance of a task carried out in the public interest or in the
exercise of any
official authority vested in us; or the purposes of the legitimate interests pursued by us or by
a third
party. If you make such an objection, we will cease to process the personal information unless
we can
demonstrate compelling legitimate grounds for the processing which override your interests,
rights and
freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing
purposes
(including profiling for direct marketing purposes). If you make such an objection, we will
cease to
process
your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or
historical
research purposes or statistical purposes on grounds relating to your particular situation,
unless the
processing is necessary for the performance of a task carried out for reasons of public
interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or
in
order to
take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your
personal data
from
us in a structured, commonly used and machine-readable format. However, this right does not
apply where
it
would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection
laws,
you
have a legal right to lodge a complaint with a supervisory authority responsible for data
protection.
You
may do so in the EU member state of your habitual residence, your place of work or the place of
the
alleged
infringement.
8.12 To the extent that the legal basis for our processing of your personal information is
consent, you
have
the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing
before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by emailing us on
dpo@millonfornhs.com
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent
by a web
server to a web browser and is stored by the browser. The identifier is then sent back to the
server
each
time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be
stored
by a
web browser and will remain valid until its set expiry date, unless deleted by the user before
the
expiry
date; a session cookie, on the other hand, will expire at the end of the user session, when the
web
browser
is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but
personal
information that we store about you may be linked to the information stored in and obtained from
cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) [authentication - we use cookies to identify you when you visit our website and as you
navigate our
website (cookies used for this purpose are: cookiebot https://www.cookiebot.com/en/);
(b) [status - we use cookies to help us to determine if you are logged into our website (cookies
used
for
this purpose are: cookiebot https://www.cookiebot.com/en/);
(c) [personalisation - we use cookies to store information about your preferences and to
personalise the
website for you (cookies used for this purpose are: cookiebot https://www.cookiebot.com/en/)
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you
visit
our
website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers
information
about
website use by means of cookies. The information gathered relating to our website is used to
create
reports
about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
11.4 We use Stripe to process payments on our website. This service uses cookies for payment
processing.
You
can view the privacy policy of this service provider at https://stripe.com/privacy.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for
doing so
vary
from browser to browser, and from version to version. You can however obtain up-to-date
information
about
blocking and deleting cookies via these links:
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by Help Lever Limited.
13.2 We are registered in England and Wales under registration number 12585550, and our
registered
office is
at 63-66 Hatton Garden, Fifth Floor, Suite 23, London, England, EC1N 8LE
13.3 Our principal place of business is at 63-66 Hatton Garden, Fifth Floor, Suite 23, London,
England,
EC1N
8LE.
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by email, using the email address published on our website from time to time.
14. Data protection officer
14.1 Our data protection officer's contact details are: dpo@millionpixelscharity.com