This policy sets out how and why SmartGiving processes the personal data (that is, information by which an individual can be identified) collected by us in the course of our lawful activities, in accordance with the Data Protection Act 2018, the General Data Protection Regulation and any associated and subsequent legislation (‘Data Protection laws’). This policy has been put in place to protect your rights under the Data Protection laws, and it is important that you understand what we will do with your data and are happy with this.
References to the processing of information includes the collection, use, storage and protection of data. SmartGiving is the ‘data controller’ for the purposes of this policy, and the policy extends to its staff, trustees, volunteers and anyone else processing data on our behalf from time to time to the extent set out below.
The Data Protection Officer, KKL Charity Accounts, Mountcliff House, 154 Brent Street, London NW4 2BF.
We may be legally required in certain instances to ask that your request for information be submitted in writing.
SmartGiving is the trading name of KKL Charity Accounts, Charity No. 1105998 and a Company registered in England No. 5118360.
Organisations are permitted to process data if they have a legal basis for doing so. SmartGiving processes data on the basis that:
Where SmartGiving relies on solely consent as the basis for processing data, we are required to obtain your explicit consent and you can modify or withdraw this consent at any time by notifying us in writing, although this may affect the extent to which SmartGiving is able to provide services to or interact with you in future.
SmartGiving may change this policy from time to time and any such changes will be published on our website and, if appropriate, notified to you by email. Notwithstanding any change to this policy, we will continue to process your personal data in accordance with your rights and our obligations in law.
This policy was reviewed in February 2021.
We collect the data necessary for SmartGiving to pursue our charitable objectives, including but not limited to providing a charity accounts service and charity fundraising facilities to facilitate online and other donations and promoting these services to those whom we think may benefit from them or from hearing about them. Accordingly, data will be processed for operational purposes, marketing, running events, keeping users or potential new service users informed of our activities and the effective running of SmartGiving through its professional staff, trustees and volunteers.
Data collected and processed may include, but not be limited to:
Personal data may be collected from you when you engage with SmartGiving and there are many occasions when this could happen, for example: if you contact us to seek advice, enquire about our services, attend or enquire about attending an event organised by us, apply for a job or volunteering opportunity, ask us a question, register for any of our mailings, bulletins or newsletters, provide some optional feedback or otherwise provide us with personal information. This may be when you phone us, go onto our website, by post, or in person.
When you visit our website, SmartGiving collects your IP address and information regarding what pages are accessed and when. An IP address is a number that can uniquely identify a specific computer or other network device on the internet. We also collect any information that you may choose to give voluntarily, such as: contact details, credit card details, interests, data protection consents, financial circumstances and tax status.
SmartGiving is a subsidiary of JNF UK and is also formally connected to KKL Executor & Trustee Company Limited, which is also a subsidiary of JNF UK. Both of these entities apply the same high standards in relation to data privacy and security as does SmartGiving. We may from time to time include information about the services they offer or campaigns they are running when communicating with you, or share limited data about you (your contact details, but not details about your SmartGiving account) with them. If you do not wish us to share even this limited amount of data, you can inform us of this in writing.
As well as using your data so we can send you communications that you have requested or information about services or activities that we believe may be of interest to you, SmartGiving may use your personal information to help us understand more about how our website is used so that we can improve it.
You, as the data subject, may request deletion of your data at any time in writing, subject to any overriding legal requirement for its retention, such as the need, where appropriate, to retain records for Her Majesty’s Revenue and Customs in relation to Gift Aid claims. We may keep such data on a ‘suppression list’ so we know not to contact you or process your data in future until further notice.
If you do not want to hear from us by a particular method, or at all, just tell us when you provide your data or at any time after that by contacting us on 020 8732 6101, at [email protected] or at the postal address given above. Please bear in mind that electronic communications such as email and SMS are the most economical ways for us to communicate with you, but some of our updates are sent by post and some contact may be by telephone.
SmartGiving uses an email newsletter to inform subscribers about our services. Users can subscribe through an online automated process but do so at their own discretion and subscription only takes place once you have given your explicit consent. Some subscriptions may be manually processed through prior written agreement with the user.
Subscriptions are taken and held securely and in accordance with the Data Protection laws. No personal details are passed on to third parties nor shared with companies/people outside of the company that operates the email platform. You may request a copy of the personal information held about you by this platform. If you would like a copy of the information held about you, please write to us by email or post.
Email newsletters may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include, but not be limited to; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
Subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is detailed at the footer of each email newsletter. If an automated system to unsubscribe is unavailable, clear instructions on how to unsubscribe will be detailed instead.
Communication, engagement and actions taken through external social media platforms that SmartGiving participates on are subject to the terms and conditions, as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage with them with due care and attention with regard to their own privacy and personal details. SmartGiving will never ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive matters to contact us through primary communication channels, such as by telephone or email.
Our website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
No one other than SmartGiving and organisations acting on SmartGiving’s behalf will process personal data collected by us. We will not sell, share, or rent this information to other third parties without your consent. From time to time, if we run an event in partnership with or using the services of another organisation, your details may need to be shared. Such other organisations will be expected to adhere to this policy and all Data Protections laws.
When you are using our secure online donation pages, your donation is processed by Cardsave who specialise in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, email us at [email protected]
You may request details of personal information which we hold about you. Any such request must be submitted in writing. A small fee may be payable if an information request is particularly onerous.
You may choose to restrict the collection or use of your personal information, but this may inhibit or limit the way in which SmartGiving is able to interact with you. You may, at any time, change your mind about what information we hold about you, or if we continue to hold it at all, subject to any legal obligation we have to retain data.
You are responsible for the accuracy of data you have provided to SmartGiving. If you believe that any information we are holding on you is incorrect or incomplete, please write to us as soon as possible. We will promptly correct any information found to be incorrect.
In the unlikely event that there is any kind of a breach of our duties and obligations under this policy or the Data Protections laws, we will take immediate steps to isolate and rectify the problem. Should the breach be serious one (where there is a risk of, for example, discrimination, damage to reputation, financial loss or loss of confidential information) we have a duty to report that matter to the individuals affected and to the Office of the Information Commissioner.
You can obtain further information about Data Protection and privacy laws and your rights by visiting the Information Commissioner’s website at: ico.org.uk/your-data-matters..
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data we process.
Persons processing data on behalf of SmartGiving do so in accordance with this policy and on the basis that SmartGiving is satisfied that they can and will adhere to our high standards for data protection and security. Any sensitive information (such as credit or debit card details) is encrypted and protected. To signify when you are on a secure page, usually, a lock icon will appear on the address bar of web browsers.
The transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. You are responsible for keeping any password you use for accessing our website (if applicable) confidential; we will not ask you for your password (except when you log in to our website).
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website to tailor it to user’s needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We may also collect and store information about your browsing device, including, where available, your IP address, operating system and browser type, together with certain anonymous statistical data about your browsing activities and patterns which does not contain any personal data.
Click here for more information about the Data Protection Act
If you do not, we may not be able to tell you about the services offered by SmartGiving as efficiently as we would like.
If you are under 16 years of age, a person legally responsible for you will need to give their consent.