Privacy Policy

Purpose of this privacy policy
This privacy policy aims to give you information on how Futurestars collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, contact us with a message or make a donation.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller
Futurestars (West and Central Africa) (registered company number 10845174, registered charity number 1177808) is the controller and responsible for your personal data. In this policy Futurestars (west and Central Africa) may be referred to by its full name or as “Futurestars”, “we”, “us” or “our”.

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Futurestars (West and Central Africa)
Email address: [email protected]
Postal address: Rushlake House, The Street, Shottisham, Woodbridge, Suffolk IP12 3ET
Telephone number: 01394 411133
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 policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in March 2019. Historic versions can be obtained by contacting us.
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 your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes email address.
• Transaction Data includes details about donations received from you.
• Technical Data includes internet protocol (IP) address, your login data (if applicable), 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.
• Profile Data includes your username and password (if applicable), donations made by you, any further information including details of your interests and preferences and feedback or comments you make when you contact us.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing and communications from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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, such as online donations. 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 policy.
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.
Your payment details
When you make a donation through our website you will need to provide some financial details so we can take payment of your donation. We have chosen to use Stripe to handle these financial transactions for us. Stripe is a very reputable specialist provider of online payment systems and is used by some of the biggest household names in the world. When you are asked to input your payment details, these are provided directly to Stripe; we do not see or have any access to this information. If you would like to learn more about Stripe and how it will keep your payment details safe you can visit its website at https://stripe.com/gb.
If you fail to provide personal data
Where we need to collect personal data to action a request you have made, and you fail to provide that data when requested, we may not be able to accommodate your request (for example, to give effect to your request that we claim Gift Aid on your donations).

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 as follows:

• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes email address.
• Transaction Data includes details about donations received from you.
• Technical Data includes internet protocol (IP) address, your login data (if applicable), 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.
• Profile Data includes your username and password (if applicable), donations made by you, any further information including details of your interests and preferences and feedback or comments you make when you contact us.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing and communications from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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, such as online donations. 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 policy.
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.

Your payment details
When you make a donation through our website you will need to provide some financial details so we can take payment of your donation. We have chosen to use Stripe to handle these financial transactions for us. Stripe is a very reputable specialist provider of online payment systems and is used by some of the biggest household names in the world. When you are asked to input your payment details, these are provided directly to Stripe; we do not see or have any access to this information. If you would like to learn more about Stripe and how it will keep your payment details safe you can visit its website at https://stripe.com/gb.

If you fail to provide personal data
Where we need to collect personal data to action a request you have made, and you fail to provide that data when requested, we may not be able to accommodate your request (for example, to give effect to your request that we claim Gift Aid on your donations).

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

• Direct interactions. You may give us your Identity and Contact Data by filling in forms on our website. This includes personal data you provide when you
• subscribe to our newsletter;
• request marketing be sent to you;
• make a donation;
• contact us with a comment or query.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• analytics providers such as Google based outside the EU;
• Contact and Marketing and Communications Data from providers of technical and delivery services such as Mailchimp based outside the EU; and
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

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 have your consent to use your data for a particular purpose.
• 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 obligation.

Please see below 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 when we wish to send fundraising communications (such as our newsletter) to you via email or text message. You have the right to withdraw consent to receiving fundraising communications at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, 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.

 Fundraising communications
We strive to provide you with choices regarding certain personal data uses, particularly around fundraising communications.

Fundraising requests from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on how you may wish to support us, or what may be of interest to you. This is how we decide which fundraising communications may be relevant for you.

We may contact you by telephone or post for fundraising purposes if you have previously requested information from us or donated to us and you have not opted out of receiving fundraising communications (either by opting out with us directly or by registering with the telephone or mail preference services or the fundraising preference service). We will only contact you for fundraising purposes by email or text where you have consented to us doing so.

We do not share your details with other charities unless you have consented
We will only share your details with other charities in order that they may contact you for fundraising purposes where you have specifically consented to our doing so.

Opting out
You can ask us to stop sending you fundraising communications by checking or unchecking relevant boxes on the forms we use to collect your information or by following the opt-out links that will appear on all fundraising communications sent to you or by contacting us at any time. You may also opt out indirectly via the fundraising preference service.
Please note that where you opt out of receiving fundraising communications from us we will still process your personal data for the other purposes outlined in this privacy policy.

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. For more information about the cookies we use, please see our cookies policy. (please link to the cookies policy, thanks)

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.

We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We use Mailchimp to manage our fundraising communications. Please note that although the Mailchimp servers on which your personal data is stored are located in the United States of America, Mailchimp has registered with the EU-US Privacy Shield. This means that Mailchimp is committed to holding your personal data securely and in accordance with EU data protection standards. Other than this, we do not transfer your personal data outside the European Economic Area (EEA).

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 will notify you and any applicable regulator of a personal data breach where we are legally required to do so.

How long will you use my personal data for?
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 our standard retention periods for our primary uses of your personal data are set out in the table below. If you require information about our retention periods for other uses of your personal data please contact us.

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click here (please link to Legal rights below, thank you) to find out more about these rights:
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 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.

Lawful basis
Legitimate Interest means the interest of our charity in conducting and managing our charity to enable us to give you 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.
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.
Consent means processing your personal data where we have your freely given, specific, informed and unambiguous consent. We will always ensure that any request for consent is clearly displayed and will require you to take an affirmative action (such as ticking a box) so it will be clear to you when you are being asked for, and when you chose to give, your consent. We will keep a record of how and when you gave consent.

Third parties
Internal third parties
Other companies that form part of the Futurestars family (meaning those companies or entities that we own or which own us).

External third parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or controllers who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS
You have the right to:

• 10.5 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• 10.6 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.
• 10.7 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 services to you. We will advise you if this is the case at the time you withdraw your consent.