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Clwyd Special Riding Centre is committed to protecting and respecting your privacy, so this policy explains when and why we collect personal information, how we use it, when and why we might share it, and how we keep it secure. It also details your rights in relation to your personal information. The policy will be updated from time to time so please check this page occasionally. Should you have any questions about this policy or your rights regarding your personal information, or if you would like to update your contact preferences, please use the following contact details:
Clwyd Special Riding Centre, Llanfynydd, Flintshire, LL11 5HN
01352 770446
info@clwydspecialridingcentre.co.uk
Who are we?
Clwyd Special Riding Centre is a registered charity (1118241) and a Company Ltd by Guarantee (06033558).
How do we collect personal information?
We may collect your information when you use our website to contact us, register for an event, register for our newsletter, make a donation, or buy something from our online shop. We may also collect your information via email, over the phone, in person, offices or shops or at an event organised by us or somebody else. Information might be provided in digital form, verbally or in writing, and be received directly from you or from a third party you have permitted to do so.
What personal information do we collect?
We might collect your title, name, address, occupation, email address, date of birth, phone numbers, emergency contact details or bank or card details to set up a single or regular payment.
Using our website
When making a payment on our website, your payment is collected by a third-party processor who specialise in secure online processing of transactions. When visiting our website, we will also record your IP address, and information regarding the pages you access. We use small files known as cookies to monitor usage of our website including visitor numbers and page views.
If you visit one of our pages that includes external content (e.g. YouTube), you may be presented with cookies from these websites; you should check these third party websites for more information about their cookies. You can disable cookies when using our website, though some of the functionality may be affected. We use Google Analytics to understand how people use our website so we can make it more effective. Google Analytics collects anonymous information about activity on our website using cookies.
Why do we collect personal information?
We only collect the minimum amount of personal information required to fulfil the purpose for which it is collected. You may decide not to provide us with your information or to request that we stop processing your information at a later date, though this may affect your ability to participate in or benefit from some of the activities undertaken by Clwyd Special Riding Centre. Personal information which we collect from you may be used in a number of ways including, but not limited to:
• Replying to an enquiry you have made to CSRC via phone, text, email or post
• Creating a record of a donation you have made or processing a regular gift
• Completing an order for something you have purchased from our online shop
• Reclaiming Gift Aid on donations from HM Revenue and Customs
• Registering you to participate in a fundraising activity
• Sending you information about the charity, our activities and our fundraising events
• Carrying out our obligations arising from any contracts entered into by you and us
• Processing entries into a competition or raffle
• Seeking your views/comments on the services we provide or activities we undertake
• Notifying you of changes to our services, events or activities
Clwyd Special Riding Centre will only process your personal data where we have a legal basis for doing so as stipulated by current data protection and privacy legislation, namely:
• Where we have your explicit consent (see below)
• In order to comply with a legal obligation
• When performing official functions or tasks in the public interest
• If it is in your or somebody else's vital interests
• To fulfil a contractual requirement
• When to do so is in our legitimate interests (see below)
Consent
Consent means offering you a real opportunity to state whether or not you wish to allow the processing of your personal information. When processing your information on the basis of consent, we will ensure you are fully aware of what you are consenting to and only use your information for that purpose. You can withdraw your consent at any time using the contact details above. We have determined that processing your personal information on the basis of consent is lawful and legitimate when:
• Sending communications to you via email/post promoting the work of CSRC and ways in which you can support us
Legitimate Interests
CSRC may undertake data processing in pursuit of our legitimate interests, where to do so will not infringe your rights or interests as the data subject. To ensure this is correctly assessed, we undertake a balancing exercise to ensure that our processing does not adversely impact you. In the case of the following data processing activities, we have determined that the processing of your information for these purposes is lawful and legitimate:
• Sending communication to you via the post/email about our work and ways you can support us
• Registering you for a fundraising event in which you wish to take part
• Processing any of your information received from a third party (e.g. JustGiving)
• Maintaining your information on our secure database to record your support
• Recording your contact details to enable collections/deliveries to addresses you provide
You have the right to object to the processing of your personal information on the grounds of legitimate interests as detailed below in 'Right to object'.
Who do we share personal information with?
CSRC will not share your information with third parties for marketing purposes and will not sell or rent your information to third parties. If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your credit card details securely to our payment processing partner as part of the payment process in accordance with the Payment Card Industry Standard. We hold details for up to 28 days for legal requirements after which they are deleted or destroyed. Clwyd Special Riding Centre may share your personal information with third parties outside of the European Economic Area if any of the exemptions detailed in the General Data Protection Regulation are met. In the case of data processors in the USA, only those certified under the U.S. Privacy Shield framework regarding the collection, storage, transfer, use and other processing of personal data will be utilised.
How do we protect personal information?
We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary. Any payment card, bank or direct debit details we receive on our website are passed securely to our payment processing provider according to the Payment Card Industry Security Standards, and all online financial transactions are encrypted using SSL (Secure Sockets Layer).
How long do we keep personal information?
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). We will hold your personal information on our systems for as long as is necessary for the original purpose, or as long as is set out in any relevant contract you hold with us.
What are your rights regarding your personal information?
Right to be informed
You have the right to be informed about the collection and use of your personal data by CSRC. Details of the types of information we collect, the purposes for which it is collected, who we share the information with and how long we retain it are detailed in this privacy policy which is updated periodically and always accessible via the Clwyd Special Riding Centre website.
Right of access
You may obtain a copy of the personal information we hold about you by submitting your request to the contact details above. We will reply within one month of receipt of your request unless there is a compelling reason to extend this response time. We may refuse a request in certain circumstances, in which our justification will be communicated to you.
Right to rectification
You have the right to have any inaccurate personal information that we may hold for you rectified (corrected) and to request that any incomplete information be completed. You can make your request using the contact details above. If we accept that your information should be rectified, we will do so within one month. In certain circumstances, we may refuse a request if we consider the request to be unfounded or excessively repetitive.
Right to erasure
You can request that the information we hold about you be deleted by contacting us using the details above and we will respond within one month. The right to erasure applies if:
• we no longer need your information for the purpose for which we collected it
• our processing of your information is based on consent, and you withdraw that consent
• processing of your information is based on legitimate interests, and you successfully object
• you object to the use of your personal information for direct marketing purposes
• your information has been processed unlawfully
• we have a legal obligation to remove your personal information
In certain circumstances, we may refuse a request for erasure if we consider the request to be unfounded or excessively repetitive, or if any of the specific provisions of the current data protection legislation apply. If we have shared your personal information with any third parties and accept your request for erasure, we will contact them accordingly so they can erase your information as well.
Right to restrict processing
You can make a request for information we hold about you to be suppressed (in other words to be stored but not used) in the following circumstances:
• you have contested the accuracy of the information we hold and we are investigating
• your information has been unlawfully processed but you want to restrict it, not erase it
• you want us to keep your information after we need it in support of a legal dispute
• you have objected to our processing of your information and we are investigating
You can make your request using the contact details above and we will respond within one month. In certain circumstances, we may refuse a request to restrict processing of your information if we consider the request to be unfounded or excessively repetitive.
Right to data portability
The right to data portability gives you the right to receive the personal information you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transfer it directly to another controller. This only applies to information stored electronically, provided directly by you and which we process based on your consent.
Right to object
You have the right to object to the processing of your personal data in certain circumstances. In the case of direct marketing, this is an absolute right. In other circumstances, we may continue the processing if there is a compelling reason for doing so, or if we consider the request to be unfounded or excessively repetitive. You can make your request using the contact details above and we will respond within one month.
Rights related to automated decisions and profiling
Clwyd Special Riding Centre does not conduct any automated decision making or automated processing/profiling.
What should you do if you have a complaint?
If you have a complaint concerning CSRC’s processing of your personal data, you can contact us using the information above. Data Protection legislation also gives you the right to lodge a complaint with a supervisory authority. More information can be found on the Information Commissioner's Office website at www.ico.org.uk.
PHOTOGRAPHY
Images are a key element in telling the story of CSRC.
The definition of the term ‘images’ refers to photographic prints or slides, digital images, videos or moving images. The images may be distributed via print, DVDs, the internet or other technologies.
Giving consent
Our participant/volunteer application forms have a section that documents the individual’s or parents/carers’ agreement or objection regarding the taking and use of images.
CSRC asks that no photography or taking of images in any form are undertaken during sessions - unless prior consent has been granted. At the time of images being taken, those in charge of the event or session should check if anyone has any objections as well as referring to the consent section on the participant’s file.
With consent, CSRC may use images:
• on our website and on social media
• offline in their journal/newsletter and promotional leaflets, and at events organised by CSRC
• for promotional materials, publications, in articles and potentially for publicity/marketing purposes
• shared with media or local press for cases such as raising the profile of CSRC
Consent to use images can be withdrawn at any time by emailing info@clwydspecialridingcentre.co.uk. Please note this will not apply to material already published. CSRC cannot control already published material or recall them.
August 2022