Privacy Policy

Introduction

Welcome to the privacy notice of The UK Foundation of the University of British Columbia.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, and it tells you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Contents:

1. 1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. 2. [THE DATA WE COLLECT ABOUT YOU]
3. 3. [HOW IS YOUR PERSONAL DATA COLLECTED]
4. 4. [HOW WE USE YOUR PERSONAL DATA]
5. 5. [DATA SECURITY]
6. 6. [DATA RETENTION]
7. 7. [YOUR LEGAL RIGHTS]
8. 8. [COOKIE POLICY]
9. 9. [GLOSSARY]

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of our website (regardless of where you visit it from), your contact and dealings with us, including providing any data through our website, when you ask us for information, sign up for updates, purchase a product or service, supply to us [or take part in any survey].

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

The UK Foundation of the University of British Columbia is the controller and responsible for your personal data (collectively referred to as “the Foundation“, “we“, “us” or “our” in this privacy notice).

We have appointed a [data privacy manager] who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights – see below, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: The UK Foundation of the University of British Columbia

Data privacy manager:  Harprit Seckhon, Company Secretary

Email address:   harprit.sekhon@ubcf.org.uk

Postal address: 67 Manor Avenue, Hounslow, Middlesex TW4 7JN, United Kingdom

Company Number:          05042921

Charity Number:              1103437

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on [04.25.2023] and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. It is your responsibility to keep us informed if your personal data changes during your relationship with us.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, [username or similar identifier,] title [marital status, gender, preferred pronoun, date of birth, passport, driving licence, and other AML required documentation].
• Contact Data includes billing address, delivery address, email address and telephone numbers (including that of your organisation or the person making a payment).
• Financial Data includes bank account, source of funds and generation of intended donation and payment card details.
• Transaction Data includes details about payments to and from you and other details of donations and services you have purchased from or supplied to us.
• Technical Data includes internet protocol (IP) address, 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 our website.
• Profile Data includes your username and password, donations made by you, [your interests, preferences, social media ‘likes’, feedback and survey responses].
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we 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/donation arrangement we have with you and you fail to provide that data when requested, we may not be able to perform our current or intended obligations (for example, to process any donation request). In this case, we may have to cancel a proposal/opportunity you have with us but we will notify you if this is the case at the time.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, EDI, our UBC social media accounts or otherwise. This includes personal data you provide when you:
• apply to make a donation;
• subscribe to our database or publications;
• request marketing/donation applications to be sent to you;
• [interact with our UBC social media accounts]
• enter a competition, promotion or survey;
• give us some feedback; or
• other interactions with us.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies [or on our social media. Please see our cookie policy below for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:

(a) analytics providers such as Google and Site Improve [inside OR outside the EU]

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based [inside OR outside] the EU.
• Identity, Technical Data and Contact Data from social media based inside or outside the EU.
• Identity and Contact Data from publicly available sources such as Companies House

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the arrangement that we are about to enter into or have entered into 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.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data, [other than in relation to sending third party direct marketing communications to you via email or text message that you have opted in to receive]. You have the right to withdraw consent to marketing at any time through our website Contact Us page.

Purposes for which we will use your personal data

We have set out below, a description of all 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.

The Foundation will share data with UBC as required to process donations.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please contact us to make certain decisions about your personal data use.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which offerings/services may be relevant for you (we call this marketing).

[You may receive marketing communications from us if you have requested that sort of information from us or you have opted-in to receiving that marketing when making a donation or entering into a competition or registering for a promotion or event.]

Website Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. See Cookie Policy, Section 10, below for more details.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and we may continue to hold personal data for the purpose of handling any complaints or for relevant litigation.

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 requirements.

By law we have to keep basic information about our customers and suppliers (including Contact, Identity, Financial and Transaction Data) for seven (7) years after they cease being customers or suppliers for tax and other legal purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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.

6. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the section headed Your Legal Rights below.

If you wish to exercise any of the rights set out above, please contact us.

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 may 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 may 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.

7. Cookie Policy

What Are Cookies

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device.

What Are Cookies Used For

Cookies allow our website to know if your computer or device has visited our site before. Cookies can then be used to help understand how our site is being used, help you navigate between pages efficiently, and generally improve your browsing experience.

Statistics cookies

Statistics cookies help us understand how visitors interact with our website by collecting and reporting information anonymously.

All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site, and will not be able to monitor its performance.

These cookies allow us to recognize and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example by making sure visitors are finding what they need easily. The information collected through these cookies include anonymous traffic statistics, like number of page views, number of visitors and time spent on each page.

You can block or delete these cookies by changing the browser settings. You can also prevent your data from being collected by Google Analytics on our website by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser.

What Are My Choices When it Comes to Cookies?

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please note that if you reject cookies or disable cookies, certain features or functions on our website may be limited.

8. Glossary

LAWFUL BASIS

Law means the Data Protection Act 2018 which is the UK’s implementation of the General Data Protection Regulation (GDPR). Everyone responsible for using personal data has to follow strict rules called ‘data protection principles’. They must make sure the information is: used fairly, lawfully and transparently.  Currently the GDPR is retained in domestic law as the UK GDPR, but the UK has the independence to keep the framework under review.

Legitimate Interest means the interest of our business in conducting and managing our activities to enable us to give you the best offering/service 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 an arrangement to which you are a party or to take steps at your request before entering into such an arrangement.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors based in the UK and EEA who help us fulfil your requests and deliver our offering to you; for example, AML search providers, credit reference agencies, couriers, payment providers, distributor partners, IT support and system administration services and so on.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• service providers who help us to operate our Website.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 an arrangement 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.