Privacy Policy

Protecting your privacy is important to us. At all times we aim to respect any personal information you share with us, or that we receive from other organisations, and keep it safe. This Privacy Notice (Notice) explains how we hold and use personal information and your rights and options in relation to it.

If you have any questions about this Notice please contact us using the details in the “Contact us” section below. This Notice contains important information about your personal rights to privacy. Please read it carefully to understand how and why we use your personal information.

Who we are
Sentebale (registered charity number 1113544) is the controller of the personal information that is collected through the website www.sentebale.org, or otherwise as set out below.

Our Patrons
Our Co-Founding Patrons are The Duke of Sussex and Prince Seeiso of Lesotho. We sometimes share personal information with them for the purposes set out in this Notice below, and they will sometimes share personal information with us where it is lawful and appropriate to do so. In those cases, we are usually sharing data with the Royal Household. For example, we may share limited information about our supporters attending an event at which our Co-Founding Patrons may be present, or our Co-Founding Patrons may share the details of individuals with Sentebale who have expressed an interest to our Co-Founding Patrons in being involved in our work and programmes.

How we collect information about you
Direct Information e.g. personal information that you give us by filling in forms on our websites or offline (including signing up to our email communications, fundraising, or making or proposing a donation), communicating with us by phone, email or letter

When you give information to us indirectly
Your personal information may be shared with us by third parties including, for example, the Royal Household or other Royal Charites (see “Will we share your personal information?” below), our partners; sub-contractors in technical, payment and delivery services; and suppliers. We will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.

When your information is available publicly
Your personal information may be available to us from external publicly available sources. For example, listed directorships, information from the electoral roll and press reports – we may obtain this personal information, for example, when undertaking due diligence on potential donors or fundraising partners to ensure they align with our mission and values, or when researching prospective donors (see “Donor profiling” below).

When you visit our website
When you visit our website, we automatically collect the following personal information:
(a) Technical information, including the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
(b) Information about your visit to the website, including the uniform resource locator (URL) clickstream to, through and from the site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
We may combine your personal information from one or more of these sources for the purposes set out in this Notice.

What personal information do we process?
We may collect, store and use the following kinds of personal information:
• name and contact details, including postal address, telephone number, email address and, where applicable, social media identity;
• financial information, such as bank and/or credit/debit card details;
• donation history and Gift Aid details;
• photographs, video or audio recordings;
• biographical information, such as your occupation (or employment history – for example if you apply for a job);
• information about your computer / mobile device and your visits to and use of our websites, including for example your IP address;
• any other information shared with us as per the section “How we collect information about you” above.

Do Sentebale collect/share sensitive personal information?
Data privacy law identifies certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health or ethnicity. In limited cases, we may collect and/or use your sensitive personal information (also known as special category data). Normally we will only do so where we have your explicit consent, but there may be other circumstances permitted under data privacy law.
For example, we may record that a person is in a vulnerable circumstance in order to comply with requirements under charity law and fundraising regulation to ensure that we do not send fundraising communications to them.

How and why we use your personal information
Your personal information, however provided to us, may be used for the purposes specified in this Notice, including:
• to provide you with services or information which you request
• to process payments from you such as donations (including Gift Aid);
• to communicate with you as set out in this Notice below (including the sections “Campaign communications” and “Administrative communications” below);
• to administer our websites and for internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
• to improve your interactions with our websites, for example by ensuring that content is presented in the most relevant and effective manner for you and for your computer;
• to report on the results and impact of our work;
• as part of our efforts to keep our websites and our internal operations safe and secure;
• to undertake donor due diligence (see section “Donor due diligence“ below);
• to administer your employment application;
• to deal with enquiries and/or complaints made by or about you;
• to audit and/or administer our accounts;
• to satisfy legal obligations which are binding on us, for example arising from contracts entered into between you and us or in relation to regulatory, government and/or law enforcement bodies with whom we may work;
• prevention of fraud, misuse of services or money laundering; and/or enforcement of legal claims

Donor profiling
To gain a better understanding of our supporters and identify prospective supporters, Sentebale may engage in ‘donor profiling’; identification of, and subsequent research into, prospective major donors and influencers – individuals, charitable trusts and companies.
This profiling, which may include identifying indicators of wealth and analysis of our database in future, will inform our fundraising strategy, helping us to provide you with relevant and effective communications and strengthening the relationship with our supporters in the most efficient way possible. As a charity, this helps Sentebale make best use of its charitable funds in order to maximise the impact it is able to deliver.
You can opt out of your personal information being used in this way. If you do not wish Sentebale to undertake donor profiling on you, then please contact us at fundraising@sentebale.org

Donor due diligence
Like many charities, we need to undertake checks on individuals who give or propose to give large donations to us, so that we are complying with our duties to protect charity funds, assets, and reputation, and to comply with the “know your donor” principles further to Charity Commission guidance, to prevent fraud, and also to ensure compliance with our own ethical policies (Due Diligence Purposes).

We may use third party suppliers to assist us with these checks, and we may obtain information from publicly available sources in order to do so. Sentebale will follow its Ethical Fundraising and Gift Acceptance Policies in the interpretation and application of due diligence findings. We will periodically review due diligence decisions in line with any future changes to the charity’s Ethical and Gift Acceptance Policies.

Information that we obtain through carrying out due diligence may be shared with other Royal Charities for Due Diligence Purposes. See “Data Sharing”.
Donor due diligence may also include information which is considered “sensitive personal data”. This may include personal information regarding racial or ethnic origins, political opinions, religious beliefs, health and also information concerning criminal offences.

Filming and photograph at events
Please note that we (or our service providers) or third party event hosts may film or photograph those attending or taking part in our events.
We may use the footage or photographs for publicity and marketing/fundraising purposes. For example, in print and/or digital material (including social media) or via external advertising and press outlets, all of which may be made available to the public.

No personal details (e.g. names) of children under 16 will be used in such materials without consent from their parent or legal guardian, but we may use images where children are incidentally pictured (for example, as part of a crowd).

Campaign communications
We will obtain your consent to contact you via email and post to use your contact details to provide you with information about our work, news and updates.
See the section “Our legal basis for processing your information” for more information about our use of legitimate interests.

We send the following marketing materials:

Updates about Sentebale’s work:
Campaigns – information about our work in southern Africa, including how you can support the work, (for example by attending events or fundraising for them), and updates about the progress of our work;
Events – including details of our challenges or other events in aid of our work. Note that if you sign up to an event we will also send you administrative communications about how you can take part. On occasion we will also send you a reminder about the same event in future years in case you want to participate in it again; and where possible we cleanse and remove out of date contact details. This helps us to improve the delivery rate of our mailings and minimise wasted expenditure.
Social media / Digital – Depending on your settings or the privacy policies for social media messaging services like Facebook, Twitter, Instagram and LinkedIn you may receive targeted advertisements about Sentebale through our use of social media audience tools.
Please refer to the individual platform to manage your social media ad preferences.

Administrative communications
In addition to the campaign communications that you receive from us, we may also communicate with you by post, telephone and e-mail in relation to administrative matters. On occasion, we will also contact you about an event that you have signed up to participate in, for example, to check that fundraising pages have been set up and to provide any other necessary information. We may still need to communicate with you for administrative purposes even where you have opted-out of marketing communications from us.

Will we share your personal information?
Sentebale do not share, sell or rent your personal information to third parties for their own marketing purposes.

Sharing with the Royal Household and Royal Charities
Due to the nature of Sentebale, in some circumstances we may share your personal information with the Royal Household – for example to provide our Co-Founding Patrons with information about our event attendees where it is reasonable and lawful for us to do so, and they may share personal information with us. Sentebale regularly consults with Kensington Palace in the planning of events which may include sharing of event attendee information as appropriate.

From time to time, we also work with The Prince’s Foundation, listed here: https://www.princeofwales.gov.uk/prince-waless-charities and The Royal Foundation https://www.royalfoundation.com/, data is shared verbally and via secure email between the Royal Charities’ representatives.

The relationship between Sentebale and the Royal Charities follows a shared operating protocol which involves a degree of relevant and proportionate ongoing information sharing within the group, carried out in the legitimate interests of both Sentebale and the Royal Charities in supporting their individual and collective aims. This is to ensure any approaches to prospective supporters are handled sensitively and proportionately, and to prevent the same supporters receiving multiple approaches at the same time from different members of the Royal Charities, where they may not reasonably expect this. This personal information may include names, contact details, philanthropic interests and some relevant biographical detail – and where strictly necessary and appropriate to protect the interests of the Royal Charities, due diligence information (see “Donor Due Diligence” above).

Other sharing purposes
We may rarely also disclose your personal information to selected third parties in order to achieve the purposes set out in this Notice, including:
• where we have your consent to do so;
• where the transfer is to a secure data processor, which carries out processing of your personal information on our behalf pursuant to a contract;
• where it is necessary to protect your vital interests, or ensure support for individuals with a particular medical condition, or to safeguard children or individuals at risk;
• where we are required by law to do so, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation.

Security of and access to your personal information
We take proportionate and appropriate measures to safeguard your personal information and to prevent the loss, destructions, misuse or alteration of it.
For example, your personal information is only accessible by appropriately trained staff and contractors, and stored on secure servers. In general, the personal information that we collect from you will be stored at a destination within the UK or European Economic Area (EEA). However, we use agencies and/or suppliers to process personal information on our behalf. Your personal information may therefore be transferred or stored outside, and/ or otherwise processed by contractors operating, outside, the UK or EEA who work for us or for one of our suppliers.

In these cases we will take all steps reasonably necessary to ensure that the recipient implements appropriate safeguards to protect your personal information (for example, by entering into a contract approved by the European Commission or, if the company is based in the US, checking that it is certified under the EU-US Privacy Shield).

The transmission of information via the internet is never completely secure, and although we do our best to protect it, we cannot guarantee the security of personal information transmitted via the internet.

Our legal basis for processing your personal information
Sentebale must rely on a lawful basis to collect and use your personal information. Data privacy law specifies six such grounds, and we consider the following to be relevant to our use of personal information:
• Where you have provided your consent – For example, to send you direct marketing by email;
• Where it is necessary so that we can comply with a legal obligation to which we are subject – For example where we are obliged to share your personal information with HMRC to process a Gift Aid declaration;
• Where it is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract – For example if you are assisting with or otherwise involved in one of our programmes under a contract;
• Where there is a legitimate interest in us doing so.

Legitimate interests
Personal information may be collected and used if it is reasonably necessary to achieve a legitimate interest (as long as that processing is fair, balanced and does not unduly impact your rights).
Where we rely on legitimate interests, depending on the activity, we may be relying on Sentebale’s legitimate interests.

Those legitimate interests include the following:
• Charity Governance, including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes;
• Administration and operational management, including responding to solicited enquires, providing information, research, donor due diligence, events management, the administration of our programme and employment and recruitment requirements; and
• Fundraising and Campaigning, including administering campaigns and donations, and sending material by post, analysis, targeting and segmentation to develop communication strategies and maintaining communication suppressions.
In general, our legitimate interests include running Sentebale as a charitable entity and pursuing our vision and mission. However, “legitimate interests” can also include your interests, such as when you have requested information or services from us.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights.

How long do we keep your personal information
Whatever your relationship with us, we will only store your personal information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements.
Usually this will be for a specified amount of time in accordance with our internal retention policy. That length of time may vary depending on the reasons for which we are processing the personal information and whether we have a legal (for example under financial regulations) or contractual obligation to keep it for a certain amount of time.

Subject to the above, generally, we typically retain personal information relating to donors and people who have taken campaign actions or signed up to our mailing lists for 6 years after their last donation or interaction with us.

Once the retention period has expired, personal information will be confidentially disposed of or permanently deleted.
If you object to further contact from us (see ‘Your rights’, below), we will keep some basic information about you on a “suppression list” in order to avoid sending you unwanted communications in the future.

Your rights
You have a number of legal rights in relation to our use of your personal information. These rights include:
Right to object – you have the right to object to processing where we are (i) relying on the legitimate interests as a legal basis, (ii) using your personal information for direct marketing or (iii) using your personal information for statistical purposes.
Right to withdraw consent – where we are using your personal information on the basis of your consent, you can withdraw that consent at any time.
Right of access – you can ask for confirmation of what personal information we hold about you and request a copy of that personal information. Provided we have successfully confirmed your identity (we need to be sure we are only releasing your personal information to you), we will provide you with your personal information subject to any exceptions that apply.
This is sometimes called a “subject access request” and can be done by writing to us at the email or postal address in the “Contact us” section below.
Right of erasure – in some cases, you can ask us to delete your personal information from our records (or to anonymise it). We may retain some limited personal information in order to ensure you are not contacted by us in the future.
Right of rectification – if you believe our records concerning you are inaccurate, you have the right to ask us to update them. You can ask us to check the personal information that we hold about you if you are unsure.
Right to restrict processing – in certain situations you have the right to ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate usage.
Right to data portability – where we are processing your personal information using automated means on the basis of consent, or to perform a contract, you may ask us to transfer it to another service provider in a usable format.

To exercise any of these rights, please send us a description of the personal information in question, along with an explanation of the rights you wish to exercise, using the contact details in the “Contact us” section below. In some cases we may ask for proof of identification or further information before we can process your request.

Please note that these rights only apply in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ – or please contact us using the details in the “Contact us” section below if you are unsure.

Third party websites
Due to the collaborative nature of our work, www.sentebale.org may contain links to other sites, including those of our delivery partners. This Notice does not cover those external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.

Changes to this Notice
We keep this Notice under regular review and may update it from time to time, so we recommend that you check it regularly. Where necessary we may also notify you of changes to this Notice by email. This Notice was last updated on 23rd May 2018.

Contact us (including complaints)
If you have any questions or concerns (including complaints) about this Notice or about the way in which your personal information is being used please let us know by contacting us in the following ways:
• by email: info@sentebale.org
• by telephone: +44 (0) 207 7300 226
• by post: Sentebale, 4th Floor, 136 Sloane Street, London, SW1X 9AY

You are entitled to make a complaint at any time to the Information Commissioner’s Office, the UK regulatory authority for data privacy (https://ico.org.uk/global/contact-us/). However, please note that we are always grateful for the opportunity to resolve your concerns before you approach the ICO, so appreciate if you would contact us in the first instance.

Any alterations to our policy on the collection or use of data will be posted on this website.

 

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