Contents
- Summary
- Our details
- Information we collect when you visit our website
- Information we collect when you contact us
- Information we collect when you interact with our website
- Information we collect when you place an order on our website
- Our use of automated decision-making and profiling
- How we collect or obtain information about you from third parties
- Disclosure and additional uses of your information
- How long we retain your information
- How we secure your information
- Transfers of your information outside the European Economic Area
- Your rights in relation to your information
- Your right to object to the processing of your information for certain purposes
- Sensitive Personal Information
- Changes to our Privacy Policy
- Children’s Privacy
- California Do Not Track Disclosures
- Copyright, credit and logo
Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
- Data controller: Christ for all Nations U.K.
- Effective Date of this policy: May 25 2018
- How we collect or obtain information about you:
- when you provide it to us (e.g. by contacting us, placing an order on our website, signing up to our mailing lists, submitting prayer requests and responding to special events / competitions or offers)
- from your use of our website, using cookies and similar technologies, and
- from third parties – Google Analytics & Facebook.
- Information we collect: Your name, contact details, payment information e.g. Credit or debit card details, bank details or payment method details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable).
- How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to communicate with you regarding the ongoing work of the Ministry, to enable us to contact you regarding the fundraising needs of Christ for all Nations, to improve our organisation and website, to fulfil our contractual obligations, to advertise our resources and services, to analyse your use of our website, and in connection with our legal rights and obligations.
- Disclosure of your information to third parties: only to the extent necessary to run our organisation (e.g. We use a third party Postal Mail service they are sent the delivery details for each mail run in order to ensure your mail is delivered to you), to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal obligations.
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.
- How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a ministry) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
- How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
- Use of cookies and similar technologies: We use cookies and similar information-gathering technologies such as web beacons including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here: www.cfan.org.uk/cookies.
- Transfers of your information outside the European Economic Area: In certain circumstances we may share limited and specific details of your information outside of the European Economic Area, with our international offices. This will only be in the event of you signing up to or purchasing a service or resource that is administrated by that local office, (e.g. School of Fire which is administered by the Australian office). In all cases of Personal data being shared outside of the EU we will seek explicit consent from you for that transfer. Where we do so, we will ensure appropriate safeguards are in place, including the EU-U.S. Privacy Shield.
- Use of automated decision making and profiling: We may use automated decision making and profiling. We may use web analytics, cookies, web beacons, submitted personal profile data, and your interactions with our website (by means of crafted links that Tag your profile with an action taken) or use targeting cookies to display information or resources to you as you visit our website or other websites around the internet (e.g. Google Adwords Advertising, Facebook Advertising).
- Your rights in relation to your information
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- not to have significant decisions made about you based solely on automated processing of your information, including profiling
- to complain to a supervisory authority
- Sensitive personal information: We do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
Our details
The data controller in respect of our website is Christ for all Nations U.K. of Highway House, 250 Coombs Road, Halesowen, West Midlands, B62 8AA - Charity number 327522. You can contact the data controller by writing to the above address or sending an email to support@cfan.org.uk. Address your letters or email to ‘The Data Protection Officer’.
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party server to host our website Platform.sh, the privacy policy of which is available here: https://platform.sh/privacy-policy. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating. Our server is located in the UK.
Use of website server log information for IT security purposes
We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: Compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: We have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: We and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Use of website server log information to analyse website use and improve website
We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
Cookies are small text files on your computer/device. They are made by your web browser when you visit a website. Every time you go back to that website, your browser will send the cookie file back to the website's server. They improve your experience of using a website, for example, by remembering your preference settings and by measuring your use of a website to ensure that it meets your needs. For further information on how we use cookies, please see our cookies policy which is available here: www.cfan.org.uk/cookies.
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit https://www.allaboutcookies.org or see our cookies policy.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: Where your message relates to us providing you with resources or services or taking steps at your request prior to providing you with our resources and services (for example, providing you with information about such resources and services), we will process your information in order to do so.
Transfer and storage of your information
Emails you send us will be stored within the European Economic Area on our servers in the United Kingdom.
Contact form
When you contact us using our contact forms throughout the website, we collect full names, email addresses, postal addresses. We also collect any other information you provide to us when you complete the contact form, (e.g. phone numbers, interests, postal addresses, prayer requests).
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
If you do not supply the optional information required by our contact form, such as phone numbers, we will not be able to respond to your enquiry by phone. (Mandatory information will be marked such that you easily recognise it as required).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: Where your message relates to us providing you with resources or services or taking steps at your request prior to providing you with our resources and services (for example, providing you with information about such resources and services), we will process your information in order to do so.
Transfer and storage of your information
Messages you send us via our contact form will be stored inside the European Economic Area on our internal servers in the UK. For contact through our third party helpdesk facility (Freshworks, https://www.freshworks.com/privacy). Our third party hosting servers are in the EU.
Phone
When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.
We record phone calls, for training and quality purposes as well as in line with our Legal obligations surrounding verbal Direct Debit creation and authorisation.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: Where your message relates to us providing you with resources or services or taking steps at your request prior to providing you with our resources and services (for example, providing you with information about such resources and services), we will process your information in order to do so.
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed internally and any recordings are kept on our United Kingdom servers.
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: Where your message relates to us providing you with resources or services or taking steps at your request prior to providing you with our resources and services (for example, providing you with information about such resources and services), we will process your information in order to do so.
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
E-Newsletter (email list)
When you sign up for our e-newsletter (email list) on our website by entering your name and email address and ticking the positive opt-in box, we collect that information in order to process that request and communicate with you.
Legal basis for processing: Your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: You give your consent to us sending you our regular email (e-newsletter, Bible studies, campaign updates, ministry emails, appeal emails, resource emails, event emails) by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third party service to send out our regular emails (e-newsletter, Bible studies, campaign updates, ministry emails, appeal emails, resource emails, event emails) and administer our mailing list, Klaviyo. https://www.klaviyo.com/privacy.
Information you submit to subscribe for our regular emails (e-newsletter, Bible study, Appeal email, ministry email) will be stored outside the European Economic Area on our third party mailing list provider’s servers in the USA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) and crafted links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates that our emails achieve. We also track the links that are clicked to assess the relevance of the links to our Partners, helping us provide more relevant, useful and usable content.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: www.cfan.org.uk/cookies.
For more information about our third party mailing list provider and how they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy.
Registering on our website
When you register and create an account on our website, we collect the following information: full name, email address, postal address, contact phone numbers and any other information you provide to us when you complete the registration form, including any optional information, such as Prayer requests.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
If you do not supply optional information requested by some of our registration forms, e.g. Phone Numbers we will not be able to respond to your enquiry by phone if that is your preferred contact method.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Registering and administering accounts on our website to provide access to content, to facilitate Prayer request submission and facilitate the running and operation of the Ministry.
Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third party hosting provider’s servers in various EU countries. Our third party hosting provider is platform.sh. Their privacy policy is available here: https://platform.sh/privacy-policy.
Information we collect when you place an order or donation on our website
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory information
When you place an order for resources or services on our website, we collect your name, email address, billing address, and shipping address. We also collect for donations (monthly and single) Gift Aid status information. For partners setting up monthly donations via Direct Debit we will collect sort code, account number, name of account holder(s) and desired payment date for the account you wish the direct debit to be taken from.
If you do not provide this information, you will not be able to purchase resources, services or give a Donation via our website or enter into a contract with us.
Legal basis for processing: Necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: We need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Optional information
We also collect optional information from you, such as your phone number. We ask if you would like to receive communications from us. For further information, see ‘Communications’ in this section below.
If you do not supply the optional information requested at checkout, such as phone number we will not be able to contact you by phone.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: To be able to contact the customer by phone where (if necessary) in relation to their order or donation.
AND
Legal basis for processing: Your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: You consent to us processing any optional information you provide by submitting that information to us.
Processing your payment
After you place an order on our website you will need to make payment for the resources or services you have ordered. In order to process your payment or donations we use third party payment processors, including Paypal, Barclaycard ePDQ, Stripe, Shopify. Your payment will be processed by the third party payment processor you choose to process your payment, via a payment gateway.
The third party payment processor you choose to process your payment collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following link(s): https://www.barclaycard.co.uk/business/privacy-and-cookie-policy, https://stripe.com/gb/privacy, https://www.shopify.com/legal/privacy & https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.
Transfer and storage of your information
Information relating to the processing of your payment maybe stored within OR outside the European Economic Area on our third party payment processor’s servers. Barclaycard ePDQ, Stripe, Shopify and PayPal will ensure GDPR laws are applied where possible. Where the servers are located outside of the EU, specific steps, in accordance with EEA data protection law, have been applied to protect your Personal Data.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Legal basis for processing: Necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: To fulfil your contractual obligation to pay for the resources or services you have ordered from us.
Communications
At checkout you will have the option of receiving Email communications from us.
You can choose not to opt-in to receiving Email communications in relation to Christ for all Nations, by simply ensuring the tick box is left empty prior to moving to the next step of the purchase or donation you are working through.
We will send you Email communications in relation to our resources and services if you do opt in to receiving them.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: Direct marketing, advertising our resources, services, events, updating you on the work and needs of Christ for all Nations, and giving you ministry opportunity by means of prayer requests, and Bible teachings.
AND
Legal basis for processing: Your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: You give your consent, via positive opt-in, to us sending you information about our resources and services, the work and needs of Christ for all Nations, and giving ministry opportunity by means of prayer requests, and Bible teaching by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to administer our mailing list, Klaviyo.
Information you submit to subscribe for our email communications will be stored outside the European Economic Area on our third party mailing list provider’s servers in the USA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) and crafted links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates that our emails achieve. We also track the links that are clicked to assess the relevance of the links to our Partners, helping us provide more relevant, useful and usable content.
For more information on how we use web beacons in our emails, see our cookies policy which is available here: www.cfan.org.uk/cookies.
For more information about our third party mailing list provider and how they use web beacons, please see their privacy policy which is available here: https://www.klaviyo.com/privacy
Non Email Communications
You can opt in to receiving direct marketing, advertising our resources, services, events, updates on the work and needs of Christ for all Nations, ministry opportunity by means of prayer requests, and Bible teachings from us by text message, phone, and post by ticking a box indicating that you would like to receive such communications.
We will send you such communications only if you opt-in to receive them.
Legal basis for processing: Consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: You give your consent to us sending you direct marketing, advertising our resources, services, events, updates on the work and needs of Christ for all Nations, ministry opportunity by means of prayer requests, and Bible teachings by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to administer our postal mailing list, ONEPOST (www.onepost.co.uk). Their privacy policy can be reviewed here: https://www.onepost.co.uk/onepost-online-privacy-policy. Information you submit to subscribe to our postal mail list will be stored within the European Economic Area on our third party mailing list provider’s servers in the United Kingdom for the express purpose of delivering your requested direct mail from us.
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include Eventbrite and Facebook.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: Where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: Where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Our use of automated decision-making and profiling
We may use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies that are non-essential to our website in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: www.cfan.org.uk/cookies.
Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
Use of automated decision making for display advertising
We may automate the display advertisements containing our resources and services on other websites you visit, based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: www.cfan.org.uk/cookies.
Logic involved: Automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: Cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies). Typically we use these cookies to enable conversion tracking to measure the effectiveness of advertising campaigns.
How to object: You can block the non-essential cookies by using browser settings and the opt out options for the specific websites that we may advertise on, currently Facebook and Google. For further information, please see our cookies policy: www.cfan.org.uk/cookies.
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Use of profiling for web analytics
Our web analytics service, Google Analytics, uses and collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (this may include the pages you visit and what you click on). We can only process information from cookies if you have not disabled them via Google on your computer in accordance with our cookies policy www.cfan.org.uk/cookies. Information collected about you, once collected, is anonymised and stored on an aggregate basis.
Logic involved: By automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our resources), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: Cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving the non-essential cookies via the cookies owner sites i.e. Google, Facebook and ShareThis) and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.
Use of profiling in marketing emails
We use web beacons AND/OR crafted links in our emails to analyse who opens our emails and what actions they take (for example, what they click on). If you do not wish to consent to their use then you need to either not subscribe or unsubscribe from our Email communications.
Logic involved: By analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: Your behaviour when you open our emails will be tracked using small gif files (web beacons) and crafted links, to measure open rates and click through rates.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Analysing the level of engagement and effectiveness of our emails and content.
Disclosure and additional uses of your information
This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
- Telephone provider, British Telecoms. Their privacy policy is available here: https://www.productsandservices.bt.com/privacy-policy/
- Email provider, Klaviyo. Their privacy policy is available here: https://www.klaviyo.com/privacy.
- Hosting provider, platform.sh. Their privacy policy is available here: https://platform.sh/privacy-policy
- Payment provider(s), including Barclaycard ePDQ, Stripe, Shopify and Paypal. Their privacy policies are available here: https://www.barclaycard.co.uk/business/privacy-and-cookie-policy, https://stripe.com/gb/privacy, https://www.shopify.com/legal/privacy and https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev
- Postal Mail service provider, ONEPOST. Their privacy policy is available here: https://www.onepost.co.uk/onepost-online-privacy-policy/
Our third party service providers are all located in the EU, apart from Klaviyo and Paypal, which are located in the USA.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering resources and services from us.
Legal basis for processing: Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: Where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: Necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: We may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the USA.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, and insurers. Further information on each of these third parties is set out below.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are Manley & Co. Their privacy policy is available here: www.manleys.uk.com. Our accountants are located in the West Midlands, United Kingdom.
Advisors
Occasionally, we obtain advice from advisors, such as accountants, solicitors and marketing professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
Our current advisors are Pearcelegal. Their privacy policy is available here: www.pearcelegal.co.uk. Our advisors are located in the West Midlands, United Kingdom.
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are Hiscox. Their privacy policy is available here: www.hiscox.co.uk. Our insurers are located in the United Kingdom.
Sharing your information within our Ministries’ group of offices, including Christ for all Nations US for internal administrative purposes, including partner, customer and employee information.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Running and managing our ministry office effectively.
AND/OR
Legal basis for processing: Necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: We need to share your information with other global offices in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract, for example, because of the services or information you have requested being administered by the other global office.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: Preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): Resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing: Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): Legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: Where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Order information: When you place an order for resources, services, or make any financial transaction to us we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: When you make an enquiry or correspond with us for any reason, whether by email, post, via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry unless you then choose to become a partner by subscribing to our email or non email communications, we will delete your information.
Non financial Partners: We retain the information you used to sign up for our communications (email and non-email) or create a user account for as long as you remain an active subscriber (i.e. you do not unsubscribe) and we have consent that is no more than 3 years old. If consent cannot be obtained or is not provided prior to a 3 year period from the last connection via email, post, web form or phone from you to us, then your data will be anonymised and your subscription and/or account closed.
Financial Partners: We retain the information you used to give a donation (single or monthly) for as long as you remain an active financial partner and we have consent that is no more than 6 years old. If consent can not be obtained or is not provided prior to a 6 year period from the last connection via email, post, web form or phone from you to us, then your data will be anonymised.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
- The purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- Whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- Whether we have any legal basis to continue to process your information (such as your consent);
- How valuable your information is (both now and in the future);
- Any relevant agreed industry practices on how long information should be retained;
- The levels of risk, cost and liability involved with us continuing to hold the information;
- How hard it is to ensure that the information can be kept up to date and accurate; and
- Any relevant surrounding circumstances (such as the nature and status of our relationship with you).
How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- Only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- Using secure servers to store your information;
- Verifying the identity of any individual who requests access to information prior to granting them access to information;
- Using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
All of your information is stored in the following European Economic Area (EEA) country: The United Kingdom.
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: Klaviyo. You can access their privacy policy here: https://www.klaviyo.com/privacy.
Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Our third party email provider, Klaviyo currently offers customers the EU Model Contract to enable the lawful flow of personal data from the EEA to Klaviyo in the United States. The EU Model Contract contains standard contractual clauses which are approved by the European Commission, and which govern the lawful transfer of data from the EEA to countries outside of the EEA.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to the Data Protection Officer, at Christ for all Nations, Highway House, 250 Coombs Road, Halesowen, B62 8AA United Kingdom, sending an email to support@cfan.org.uk or using our Subject Access Request and Subject Removal Request forms :
- To request access to your information and information related to our use and processing of your information;
- To request the correction or deletion of your information;
- To request that we restrict our use of your information;
- To receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- To object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- To withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent. Please use our form for this purpose.
- The right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
- https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
- https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise by writing to the Data Protection Officer, at Christ for all Nations, Highway House, 250 Coombs Road, Halesowen, B62 8AA United Kingdom, sending an email to support@cfan.org.uk
- To object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
- To object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- Clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- Sending an email or letter to the address’ highlighted above, advising that we change your contact preferences and what they are now to be, i.e. removal from the email and/or mailing list(s).
- By Phone using +44(0)1216022000, advising that we change your contact preferences and what they are now to be, i.e. removal from the email and/or mailing list(s).
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: www.cfan.org.uk/cookies.
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we do not knowingly contact or collect information from persons under the age of 16. The website is not intended to solicit information of any kind from persons under the age of 16.
It is possible that we could receive information pertaining to persons under the age of 16 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 16, please do so by sending an email to support@cfan.org.uk.
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: www.cfan.org.uk/cookies.
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.