Privacy and Data Protection Policy
1. Information about us
www.savetheelephants.org is a site operated by Save The Elephants. We are a registered UK charity and our registration number is 1118804. Our main trading address is Save The Elephants, Marula Manor, Marula Lane, Nairobi, Kenya.
- Save The Elephants is committed to protecting and respecting your privacy. We are responsible for protecting your personal information as a “data controller” under applicable data protection legislation. If you have any queries about this Policy or how we use your personal information, please contact us using the details at Contact Us.
This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
As part of our work, we share data with Wildlife Conservation Network, of whom we are a founding partner. Wildlife Conservation Network is a United States of America (USA) based 501 non-profit organization that works with conservationists from around the world and is dedicated to developing community-based projects that help wildlife and people co-exist (501c3 tax exempt ID #30-0108469). We share data with Wildlife Conservation Network in order to receive donations from our supporters based in the USA, and to provide those supporters with information about our activities.
Our nominated person for data protection is Gemma Francis and their contact details are email@example.com.
2. What information do we collect?
We collect personal data as defined by applicable data protection legislation (‘personal information’).
We collect information about:
- Service users and beneficiaries;
- Donors and supporters;
- Service providers and contractors;
- Media contacts;
- Donation history;
- Correspondence; and
- Information about what level of support might be appropriate for us to ask you for.
- The personal information we collect might include name, date of birth, email address, postal address, photographs, payment details and telephone numbers.
3. How do we collect information?
If you are an employee or provide services to Save The Elephants, we will collect information in line with your contract of employment or contract for services.
If you have made a financial donation to or otherwise supported the charity, we will collect information about your donation history.
We may collect information that is available in the public domain, for example: newspaper or online media items, publicly available posts on LinkedIn or social media or Companies House listings.
We record your requests for information and any feedback we receive from you.
We obtain personal information from you when you use our website, enquire about our activities, register with us, send or receive an email, ask a question or otherwise provide us with personal information.
We may also collect technical information relating to your use of our website, including your browser type or the Internet Protocol (IP) address used to connect your computer to the internet.
We also gather general information about the use of our website, such as which pages users visit most often and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in emails. We may use this information to personalise the way our website is presented when users visit, to make improvements to our website and to ensure we provide the best service for users. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our website.
We may also receive information about you from third parties, for example from Wildlife Conservation Network, or from individuals or third party organisations who share our interests and may introduce you to us.
4. Why do we collect this information?
We collect this information for the purpose of conducting and managing our work to achieve our charitable purpose. This includes managing our staff and business functions, our relationships with donors, and our fundraising activities. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To perform our obligations under a contract to which you are a party.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. ‘Legitimate interest’ means the interest of our charity in conducting and managing our work to achieve our charitable purpose as effectively as possible. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to process your data in order to comply with our legal obligations.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct fundraising communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5. How do we use this information?
We will use your personal information:
- to promote the charitable aims of Save The Elephants;
- to provide you with information you have requested;
- to provide you with information about future events and projects we are involved in that we think may be of interest to you;
- to make suggestions and recommendations to you about projects that may interest you; and
- to notify you about changes to our services; as part of our efforts to keep our site safe and secure; and to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will only use your personal information for electronic marketing purposes if we are allowed to do this by law or if we have your consent. If you agree to us providing you with marketing information, you can always opt out at a later date. If you would rather not receive marketing material from us, please let us know at any time using the contact details at Contact Us or by Updating Your Preferences.
Additional uses of data that we receive from Wildlife Conservation Network
The information provided to us by Wildlife Conservation Network may include a profile of your interests and preferences, based on analysis by Wildlife Conservation Network, so that we can contact you in the most appropriate way and with the most relevant information. This helps us to gain a better understanding of your interests, how you are engaging with us, and how you might be willing to support us and accordingly the amount of support that it might be appropriate for us to ask you for. Where we combine this personal information with data from external sources, this helps to increase our understanding of broader demographic and geographic trends.
We want to make sure we use our resources as effectively as possible to help us engage with our community of supporters appropriately. In order to achieve this we may analyse the wealth of our supporters using the personal data we receive from the Wildlife Conservation Network’s database (sometimes known as ‘wealth screening’). This enables us to better target our conversations about fundraising and therefore generate funds cost-effectively.
6. Do we share your information with anyone else?
We share your personal information with:
- Wildlife Conservation Network if you have donated through that organisation;
- tax authorities, regulators and other authorities acting as data controllers who require us to provide information in certain circumstances, including the Kenya Revenue Authority; and
- other organisations such as registered charities which share our aims.
We may share your personal information with third parties for marketing purposes in accordance with Your Preferences. If you do not want us to share your personal data with any third party for marketing purposes, please let us know using the contact details Contact Us or by Updating Your Preferences.
We may need to provide your information to our contractors and suppliers who provide services on our behalf, to the extent necessary to enable you to receive those services.
We may share your information with the service providers or other associated organisations as identified in this policy to use the information for their own purposes as described above.
We may also need to disclose your information if required to do so by law or as expressly permitted under applicable data protection legislation.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7. International transfers
When we transfer your information between the UK and our office in Kenya, and between ourselves and Wildlife Conservation Network, this involves transferring your data outside of the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as would be afforded within the EEA by ensuring at least one of the following safeguards is implemented:
- Transfers of data outside the EEA are governed by an agreement that incorporates specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
- The country to which the data is transferred has been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. How long do we keep your information for?
We keep your information for no longer than is necessary, as set out in our record of processing which you can request by contacting us. We will retain your information for any period required by law, for example for compliance with HMRC requirements. Where we are not under a legal obligation to retain your information, we will determine what is necessary by reference to the lawful basis for processing set out above and our legitimate interests.
If you have any questions about how long we keep your information, please contact us via e-mail at firstname.lastname@example.org or write to us at Save The Elephants, P.O. Box 54667-00200, Marula Manor, Marula Lane, Nairobi, Kenya.
9. How do we protect personal information?
We take appropriate technical and organisational measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. We protect your information in accordance with the IT Security Policy of our CRM service provider – Salesforce.
We use a secure service when you make a donation through our website, via a virtual gateway operated by PayPal and/or Just Giving. Our online payment system is Payment Card Industry Data Security Standard compliant.
You should be aware that the use of the Internet is not entirely secure and although we will do our best to protect your personal data we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features such as encryption to try to prevent unauthorised access.
10. Your Rights
You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’). You also have the right to be informed of the safeguards we have in place relating to any transfers of your information to another country or to an international organisation.
You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (‘right to rectification’). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided us with changes, for example if you change your email address, name, payment details, or if you wish to cancel your registration, please let us know using the contact details at the end of this policy.
You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’). This right does not apply where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest.
You have a right to ask us to restrict our processing of your information (‘right to restriction’) if:
- you contest its accuracy and we need to verify whether it is accurate
- the processing is unlawful and you ask us to restrict use of it instead of erasing it
- we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims
- you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests.
- you exercise your right to restrict processing, we would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons.
- you have a right to prevent us from processing your data for the purposes of marketing.
If you would like to exercise any of your rights above, please let us know using the contact details at the end of this policy. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office. You may do so by calling their helpline at 0303 123 1113.
12. Changes to this policy