Policy last updated 10 December 2020
Alike (we) are committed to protecting your personal data and respecting your privacy.
This policy applies to your use of our website atwww.alike.org.uk (website).
Important information and who we are
Our full details are:
- Full name of legal entity: Alike
- Data Privacy Manager
- Email address: firstname.lastname@example.org
- Postal address: Alike, Soho Works, 180 the Strand, London. WC2R 1EA.
This version was last updated on the date at the top of this policy. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the website.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Transaction Data.
- Financial Data
- Technical Data
- Device Data.
- Log Data
- Content Data.
- Profile Data.
- Usage Data.
- Marketing and Communications Data.
- Special Category Data which may include information about your health such as information about the type and stage of cancer you may have and your treatment.
We explain these categories of data here [LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATA BELOW].
We also collect Special Category Data about you. Mainly this will be about your health but it may include other data such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions. We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information you give us about you by filling in forms on the website or by corresponding with us (for example, by email or chat). It includes information you provide when you register on our website, details of your marketing and communications preferences, information provided when you enter a competition, promotion or survey, and when you report a problem or request support for our website, our App or any other services. If you contact us, we will keep a record of that correspondence. This may also include telephone calls, emails and post. It may also include information we collect from you as a result of any monitoring which may take place. We may monitor (which may include recording) certain interactions between us in order to comply with any legal obligations, to detect fraud or criminal activity as well as for training purposes.
- Information we receive from other sources including third parties and publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Device Data and Technical Data from the following parties:
analytics providers such as Google and Apple based outside the EU;
search information providers such as Google based inside and outside the EU.
- Identity and Contact Data from social media services as part of our customer verification and anti-fraud measures
- Information from other users of the website or our App or third parties if we receive any complaints about you (for example of harassment or sending inappropriate messages)
- Identity and Contact Data from publicly available sources such as internet searches; and
- Log in authentication for assisting in authenticating you such as Facebook or Google login .
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing. We will usually only ask for your consent to process Special Category Data (such as health data) or when we would like to provide marketing information to you (including information about other products and services). Without your consent, in some circumstances, we may not be able to provide you with and you may not be able to benefit from some of our services. Where you provide Special Category Data about a third party, we may ask you to confirm that the third party has provided his or her consent for you to act on their behalf.
- Where we need to perform a contract we are about to enter or have entered with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
- Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claim or where we want to pursue any legal claims ourselves
Click here [LINK TO GLOSSARY: LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We will not share any of your health or other Special Category Data with third party without your consent.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing
To register you as a user and to help verify your identity
performance of a contract with you
To manage our relationship with you including your use of the website, notifying you of changes to the website or our Services
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how stakeholders use our products/ Services, to manage the Services and our website, to notify you of security concerns and issues and deal with complaints from others)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our Services and to develop and improve them, our website and the App)
We will use survey information for the purposes described when we collect the data (although we may use anonymised data from the survey in order to undertake research and trends)
If you have consented to us contacting you in relation to a survey, we may do so.
For prizes and competitions, we may contact you in connection with the administration of those competitions.
To administer and protect our organisation and this website including troubleshooting, data analysis and system testing
All categories of data
Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network and website security) and to safeguard our users, to test and upgrade our website, Services and processes
Your consent where this is required by law
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
Marketing and Communications
Your consent for marketing activities
To enable our staff to provide helpline services and other support
To provide customer services
Marketing and Communications
Necessary for our legitimate interests (to develop our Services and website and grow our organisation)
For research and analytical purposes to help improve our App, website and Services
All categories of data
Necessary for our legitimate interests (to develop our Services, website and App and grow our organisation)
Consent for Special Category Data and other data where your consent is required to process this data for this purpose.
Fundraising and Donations and to transact with you whether paid or unpaid
Our legitimate interest (in raising funds for our organisation)
Disclosures of your personal data
We may disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, if you have consented to this, to protect our rights and property and the rights, safety and property of others (provided we comply with data protection law).
We may also transfer your personal data to a third party we have appointed to provide services to us on our instructions which we refer to as External Third Parties as set out in the [Glossary].
If we reorganise our business as we may need to transfer information about you to another member of our group so that we can continue to provide the Service to you.
While we do not routinely transfer your personal data outside the European Economic Area (EEA) should we do so, we will only do this as permitted by data protection legislation.
All information you provide to us is stored on secure cloud servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
Certain Services include social networking, chat room, messaging or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In most cases, we will keep your information for three years after our relationship with you ends but where we have a contract with you, we will keep it for at least 6 years. It will vary depending on what data we hold, why we hold it and what we are obliged to do by law. Further details of our data retention policies can be obtained by writing to the address above.
In some cases, such as if there is a dispute or a legal action affecting the information we may need or be required to keep personal information for longer.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data for at least 6 years.
In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the website for a period of time then we may treat the account as expired and your personal data may be deleted.
Your legal rights
Under certain circumstances you have the following rights under GDPR (prior to 31 December 2020 and the Data Protection Act 2018 from 1 January 2021) in relation to your personal data.
Please click on the links below to find out more about these rights:
- [Request access to your personal data.]
- [Request correction of your personal data.]
- [Request erasure of your personal data.]
- [Object to processing of your personal data.]
- [Request restriction of processing your personal data.]
- [Request transfer or your personal data.]
- [Right to withdraw consent.]
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at email@example.com or Postal address: Alike, Soho Works, 180 the Strand, London. WC2R 1EA.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our organisation to enable us to give you the best service/product and the best and most secure experience. 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Your usage of the website and us making it available to you is a contract between us
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External third parties
Service providers acting as processors based in the United Kingdom, who provide IT and system administration services primarily Amazon using Amazon Web Services and Google.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, regulators (such as the Charities Commission) and insurers based in the UK who provide services to us.
Web developers who are engaged to write our software. We will minimise any access they have to your personal data.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK.
Marketing and other agencies that we may appoint.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Description of categories of personal data
- Identity Data: first name, last name, username or similar identifier, marital status, title, date of birth, gender, other biographical information you provide, your photographs.
- Contact Data: addresses, email addresses and telephone numbers.
- Financial Data: bank account and payment card details.
- Transaction Data: includes details about payments to and from you and details of donations.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Where you use a mobile device to access the website, this includes Device Data
- Device Data: includes the type of mobile or other device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your device operating system, the type of mobile browser you use, and time zone setting.
- Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content.
- Profile Data: includes your username and password, posts, body, purchase history, your interests, preferences, feedback and survey responses.
- Usage Data: includes details of your use of the website including.
- Log Information details of your use of the website.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Category Data includes information about your health, diagnosis, current status, but it may include other data such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions.