- Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls within the customer account area of our website.
- How we use your “personal data”
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name, email address, telephone number, fax number, newsletter subscription preference and postal address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.
2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, select payment details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 Financial transactions relating to our website and services may be handled by our payment services providers as listed within our checkout pages. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices on their own company websites.
3.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We and our other group companies have offices and facilities in the United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the Information Commissioner’s Office.
4.3 The hosting facilities for our website are situated in the United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from the Information Commissioner’s Office.
4.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data for a minimum period of 30 days following its provision.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on its necessity for the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or other means of communication.
- Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request a copy of the personal data we hold by contacting us. Please note that we may in return request copies of valid identification.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
- Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Personal data of children
9.1 Our website and services are targeted at persons over the age of 16.
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
- Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
- About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
12.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website.
(b) status – we use cookies to help us to determine if you are logged into our website.
(c) shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website.
(d) personalisation – we use cookies to store information about your preferences and to personalise our website for you.
(e) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
(f) advertising – we use cookies to help us to display advertisements that will be relevant to you.
(g) analysis – we use cookies to help us to analyse the use and performance of our website and services.
(h) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
- Cookies used by our service providers
13.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
13.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
13.3 We may publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
- Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
- Cookie preferences
15.1 You can manage your preferences relating to the use of cookies on our website by following the steps in section 14 most relevant to your web browser software.
15.2 Please note that if you block cookies, you may not be able to use all of the features on our website. This may also “break” certain elements of our website and prevent them from functioning correctly for you only.
- Our details
16.1 This website is owned and operated by Fife Society for the Blind. We are registered as a Scottish Registered under registration Charity No. SC001354 and as a Limited Company registered in Scotland (No.164278), and our registered office is at Wilson Avenue, Kirkcaldy, Fife KY2 5EF.
16.2 Our principal place of business is at Wilson Avenue, Kirkcaldy, Fife KY2 5EF.
16.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
- Representative within the European Union
17.1 You can contact our Representative within the European Union with respect to our obligations under data protection law using any of the contact methods listed in section 16.3.
- Data protection officer
18.1 You can contact our Data Protection Officer with respect to our obligations under data protection law using any of the contact methods listed in section 16.3.
seescape privacy statement
seescape is the operating name of Fife Society for the Blind which is a charity registered in Scotland, number SC001354, and is a company limited by guarantee registered in Scotland number 164278.
We are a data controller which means that we determine the purposes for which, and the manner in which, any personal data are, or are to be, processed. We are registered as a data controller with the Information Commissioner’s Office, registration number: Z7547301.
We process personal information as the provider of specialist services in Fife to people with sight loss and process personal data for our service users and their families; employees, contractors, consultants, volunteers, trustees, suppliers, clients and individual contacts e.g. fundraising database.
We are committed to protecting the privacy and security of personal information and being transparent about what we do with it. This privacy statement describes how we collect, hold and use personal information.
We will only use your information for the purpose for which it was provided.
We will only share your personal information with the organisations and/or individuals you have consented to unless we have a legal obligation to disclose your information.
We will only share relevant and necessary information.
We will never share or sell your information to other organisations for marketing, market research or commercial purposes.
Ways in which we collect personal information:
Directly from you
Examples of this would be when:
• you request support or services from us
• you become a trustee
• you apply for a job or volunteering role with us
• you donate to us
• you order or buy aids or equipment from us
• when you supply goods or services to us.
If you write to us or email us we may keep a record of that correspondence and the response we make. If you telephone or text us we may record or copy the content in order to respond to you.
From another source
Examples of this would be when:
• you have given your consent to the NHS to share your Certification of Visual Impairment with us
• you have given your consent (to another agency, to a family member or to a friend/carer) to be referred to us for support
• from fundraising giving platforms
From our website
When you use the contact form on our website to get in touch with us. We will record the information required to process your request.
If you visit our website we may record the details of your visit including, but not limited to, traffic data, location data, web logs, communication data and the resources that you access and use. We may collect information about your computer, including where available your IP address, operating system and browser type.
Cookies
‘Cookie’ is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or table when you visit a website. They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, cannot be used to identify you.
We may use ‘cookies’ to monitor how people use our site. This helps us to understand how people use our website so we can develop and improve the design, layout and function of the sites.
You can normally alter the settings of your browser to prevent it from accepting cookies.
By using our website you consent to our use of cookies in accordance with the terms of this policy.
How we will use your personal information
When we collect your personal information, we will provide you with information about how it will be used.
Legal basis for using your information
In some cases, we will only use your personal information where we have your consent to do so.
In other cases, depending on your relationship with us, we may need to use your personal data where it is relevant and appropriate for us to do so. This means we use legitimate Interest as the basis for using your personal information. Examples of this would be:
• to send clients essential information about our organisation
• to send clients information about our services and support, events and activities or our fundraising efforts, unless they have told us they do not want such information
• to process an order for aids or equipment
• to carry out research to help us develop and improve our services
• for our recruitment and selection process and for employment purposes
• for our trustee recruitment and selection process and governance matters
• to manage company membership
• to record donations, including related payment details
• for our volunteer recruitment and selection process and for volunteer management purposes
• for service agreement or contract management
• for supply management.
When considering if the use of your personal information is relevant and appropriate to how you are involved with us, we always assess your data protection rights and our business interests to ensure they are balanced. Please contact us should you have any queries about this.
Keeping in touch with you about our work
We will use your personal information to send you information about:
• our services and support, including events and activities
• our fundraising efforts.
However, we will not send you such information if you have asked us not to. Please contact us should you want us to stop sending you information about our work or if would like to receive it by a different method.
We will never share or sell your information to other organisations for marketing, market research or commercial purposes.
Who we share your information with
When we collect your personal information, we will provide you with information about who we may, or will, share it with.
Where we require your consent to share your information we will explain this to you and obtain your consent before sharing your information with another organisation or individual.
We will only share relevant and necessary information.
Where we need to share your information for contractual, regulatory or legal reasons we will provide you with information to explain this.
When we share information with suppliers, or others who provide services on our behalf, for example, payroll and pension services, transport providers or activity providers, we will only provide them with the personal information they need to know. We will check that they have appropriate data protection measures in place to protect your information.
How we keep your personal information secure
We have implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on electronic and paper-based systems. This protection covers improper access, use, alteration, destruction and loss.
Depending on why you provided us with your personal information and how we are using it, we may need to transfer your information outside the EU, (for example some of the systems we use to hold personal information may be provided by an organisation that stores the data on computer systems held outside the EU). Although the country may not be subject to the same data protection laws as companies based in the UK, we will endeavour to make sure they provide an adequate level of protection in accordance with UK data protection law or ensure that safeguards are put in place to protect your personal information.
Our website
Although we do our best to protect your personal information sent to us via our website contact form, we cannot guarantee the security of data transmitted to our website.
Our website contains links to other sites. We are not responsible for the content or the privacy practices employed by other sites. This privacy statement does not cover the information practices of those websites or advertisers.
We will not sell any information about your web browsing activity.
How long we keep your personal information for
We will keep your personal information securely for as long as we need to for the purposes we collected it and in accordance with our records retention schedule.
Your rights over your data
You have the following rights in respect of the personal information we hold about you:
• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.
Please note, some of your rights only apply in certain circumstances and we may not be able to fulfil every request. Please contact us should you have any queries.
Amendments
We may update this policy from time to time by publishing an updated version on our website.
Contact us
If you have any queries about your rights and our responsibilities in respect to your personal information, please contact the Chief Executive, seescape, Wilson Avenue, Kirkcaldy KY2 5EF, telephone 01592 644979 or email to info@seescape.org.uk
You can also contact the Information Commissioner’s Office on 0303 123 1113 or visit their website for more information at www.ico.org.uk