This policy describes how and why Turkey Mozaik Foundation uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information. We promise to respect all of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it.
Our use of personal information allows us to make better decisions, fundraise more efficiently and, ultimately, helps us reach our goal of empowering the civil society organisations in Turkey in the areas of children, women, education, environment and health.
This policy is effective from 25 May 2018.
WHO WE ARE
HOW WE COLLECT YOUR INFORMATION
Information you provide to us directly
You may give us your information in order to sign up for one of our events, make a donation, purchase our products, register as a volunteer, media volunteer or ambassador for us, join our support network or otherwise communicate with us.
When you use our website, we collect your personal information using “cookies” and other tracking methods. In addition, in accordance with common website practice, we will receive information about the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
Information you provide to us indirectly
Your information may be shared with us by third parties, for example:
- Professional fundraising agencies;
- Independent event organisers, for example the London Marathon or fundraising sites like Just Giving or Virgin Money Giving;
- We also may receive data about you from subcontractors acting on our behalf who provide us with technical, payment or delivery services, and from business partners, advertising networks and search/analytics providers used on our website.
Information from other sources
We also use information from the following sources:
Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those services, for example when you publicly tag us in an event photo.
Information available publicly
We supplement information on our supporters with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of TMF. For more information, please see our section on “Building profiles of supporters” below.
WHAT PERSONAL INFORMATION WE COLLECT
We collect, store and use the following kinds of personal information:
- your name;
- your contact details (including postal address, telephone number, e-mail address and/or social media identity);
- your date of birth;
- your gender;
- your bank or credit card details where you provide these to make a payment;
- information about your activities on our website and about the device you use to access these, for instance your IP address and geographical location;
- information about events, activities and products which we consider to be of interest to you;
- where you have left us a legacy, any information regarding next of kin with which you may have provided us to administer this;
- information as to whether you are a taxpayer to enable us to claim Gift Aid;
- any other personal information you provide to us.
Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. An example of this type of sensitive data would be information about health. We only collect this type of information about our supporters to the extent that there is a clear reason for us to do so, for example asking for health information if you are taking part in a sporting event such as an organised run or walk, or where we ask for information for the purpose of providing appropriate facilities or support.
Wherever it is practical for us to do so, we will make why we are collecting this type of information clear and what it will be used for.
HOW WE USE YOUR INFORMATION
We will use your personal information to:
- administer your donation or support your fundraising, including processing Gift Aid;
- keep a record of your relationship with us;
- respond to or fulfill any requests, complaints or queries you make to us;
- understand how we can improve our fundraising information by conducting analysis and market research;
- manage our events;
- check for updated contact details against third party sources so that we can stay in touch if you move (see “Keeping your information up to date” below);
- further our charitable objectives;
- send you correspondence and communicate with you;
- process applications for funding and for administration of our role in the projects we fund;
- administer our websites and to troubleshoot, perform data analysis, research, generate statistics and surveys related to our technical systems;
- testing our technical systems to make sure they are working as expected;
- contact you if enter your details onto one of our online forms, and you don’t ‘send’ or ‘submit’ the form, to see if we can help with any problems you may be experiencing with the form or our websites;
- display content to you in a way appropriate to the device you are using (for example if you are viewing content on a mobile device or a computer);
- generate reports on our work, services and events;
- safeguard our staff and volunteers;
- conduct due diligence and ethical screening;
- monitor website use to identify visitor location, guard against disruptive use, monitor website traffic and/or personalise information which is presented to you;
- process your application for a job or volunteering position;
- conduct training and quality control;
- audit and administer our accounts;
- meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies;
- carry out fraud prevention and money laundering checks;
- undertake credit risk reduction activities; and/or
- establish, defend or enforce legal claims.
HOW WE USE YOUR INFORMATION TO TELL YOU ABOUT OUR WORK
Sending marketing communications
Our marketing communications include information about our latest grants, campaigns and requests for donations or other support. Occasionally, we may include information from partner organisations or organisations who support us in these communications. We operate an ‘opt-in only’ communication policy. This means that, except as set out below, we will only send marketing communications to those that have explicitly stated that they are happy for us to do so. The marketing information will be included within our newsletter.
We may use information you have given us directly, for example the record of your previous donations to and/or relationship with us, your location and demographics, as well as the type of activity you have been involved with, to tailor our communications with you about future activities.
Events and fundraising
When you have asked for details of a TMF event, we will send you information including, where relevant, ideas for fundraising and reminders on key information about the activity.
Where you have signed up for an event with a third party (for example the London Marathon) and told the event organiser that you wish to fundraise for us, we may contact you with information and support for your fundraising for that event.
Managing your contact preferences
We make it easy for you to tell us how you want us to communicate, in a way that suits you. We include information on how to opt out when we send you marketing. If you don’t want to hear from us, that’s fine, and you can change your preferences at any time. Just let us know when you provide your data or contact us at email@example.com.
If you’ve decided you don’t want to be contacted for marketing purposes, we may still need to contact you for administrative purposes. This may include where we are processing a donation you’ve made and any related Gift Aid, thanking you for a donation or participation in an event, or keeping in touch with you about volunteering activities you are doing for us.
Building profiles of supporters
By developing a better understanding of our supporters we can tailor and target our fundraising events and communications (including volunteering opportunities) to those most likely to be interested in them. This allows us to be more efficient and cost-effective with our resources, and also reduces the risk of someone receiving information that they might find irrelevant.
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation.
LEGAL BASIS FOR PROCESSING
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via post, phone, text or e-mail). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, Fundraising Regulator, Information Commissioner or Gambling Commission, or to use information we collect about you for due diligence or ethical screening purposes.
Performance of a contract / take steps at your request to prepare for entry into a contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are buying something from us (for instance some branded merchandise or, in some cases, an event place), applying to work/volunteer with us, or being funded to undertake research.
We have a basis to use your personal information where it is necessary for us to protect life or health. For instance if there were to be an emergency impacting individuals at one of our events, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
We consider our legitimate interests to include all of the day-to-day activities Turkey Mozaik Foundation carries out with personal information. Some examples not mentioned under the other bases above where we are relying on legitimate interests are:
- analysis and profiling of our supporters using personal information we already hold;
- updating your address using third party sources if you have moved house (please see the “Keeping your information up to date” section below for more on this).
- use of personal information when we are monitoring use of our website or apps for technical purposes;
- use of personal information to administer, review and keep an internal record of the people we work with, including supporters, volunteers and grantees;
- where you have signed up with us on a charity place for a third party event (for example a sponsored run not organised by TMF), sharing personal information with the third party event organiser so they can administer the event.
We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.
When we use sensitive personal information (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will do so on the basis of your explicit consent unless the information is available publicly and lawfully.
HOW WE KEEP YOUR INFORMATION SAFE
We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details. Where we use a third party services, they are routinely monitored to check their ability and reliability to keep our and your information safe.
HOW LONG WE KEEP YOUR INFORMATION FOR
TMF has specific criteria to determine how long we will retain your information for, which are determined by legal and operational considerations.
SHARING YOUR INFORMATION WITH OTHERS
As set out in the “Sending marketing communications” section above, we will never sell or rent your information to third parties for marketing purposes. However we may disclose your information to third parties in connection with the other purposes set out in this policy. These third parties may include:
- business partners, suppliers and sub-contractors who may process information on our behalf;
- if you are a researcher, volunteer advisory panels, any joint funders of research, host institutions and external members of our committees;
- advertisers and advertising networks
- analytics and search engine providers;
- IT service providers.
Some of our suppliers may run their operations outside the European Economic Area (EEA) – this may include a country which may not be subject to the same data protection laws as companies based in the UK. In these circumstances, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law, and appropriate safeguards are in place.
Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors.
Under UK data protection law, you have rights over personal information that we hold about you. Below is a summary:
Right to access your personal information
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your information, please contact us at firstname.lastname@example.org
Right to have your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. If you believe the information we hold about you is inaccurate or incomplete, please provide us with details and we will investigate and, where applicable, correct any inaccuracies.
Right to restrict use of your personal information
You have a right to ask us to restrict the processing of some or all of your personal information in the following situations: if some information we hold on you isn’t correct; we’re not lawfully allowed to use it; you need us to retain your information in order for you to establish, exercise or defend a legal claim; or you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so.
Right to erasure of your personal information
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, you have the right for this to be done.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object to the use of your personal information
If we are processing your personal information based on our legitimate interests you have a right to object to our use of your information.
If we are processing your personal information for direct marketing purposes, and you wish to object, we will stop processing your information for these purposes as soon as reasonably possible.
If you want to exercise any of the above rights, please contact us at email@example.com
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office (ICO (link is external)).
If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. We appreciate the opportunity this feedback gives us to learn and improve. Please contact us at firstname.lastname@example.org
You also have the right to lodge a complaint about any use of your information with the Information Commissioners Office (link is external), the UK data protection regulator.
CHANGES TO THIS POLICY
Best way to contact us is through email: email@example.com.