WHO ARE WE?
HOW CAN YOU CONTACT US?
HOW DO WE COLLECT YOUR INFORMATION?
We may collect information about you directly whenever you interact with us. For example, when you contact Change Nigeria Project regarding our activities, register as a supporter, send or receive information, engage with our social media or make a donation to us, you may provide us with your personal information.
We may also receive information about you when you interact with third parties with whom we work. For example, where you’ve made a donation to us through a third-party website (e.g., Just Giving or Virgin Money Giving) and given them permission to share your information with us.
We may supplement what we know about you with information that is available to the public. For example, in order to ensure that our communication with you is relevant and tailored to your background and interests, we may collect information about you from publicly available sources either directly or through third-party subscription services or service providers. We may also carry out research using publicly available information to identify individuals who have an affinity with our cause but with whom we are not already in touch.
WHAT INFORMATION DO WE COLLECT?
The information we collect from you directly or from third parties with whom we work, may include:
We may also collect and process information about your interactions with us, including details about our contacts with you through email, SMS, post, on the phone or in person (i.e., the date, time, and method of contact), details about donations you make to us, events or activities that you register for or attend and any other support you provide to us. We may also collect and record any other relevant information you share with us about yourself, including your interests or your affiliations with other charities, community groups, your employer or a Change Nigeria Project corporate partner. If you are a minor, we may collect the name and contact details of a parent or guardian and, where appropriate, the name and location of your school.
In order to ensure that our communication with you is relevant and tailored to your background and interests, we may supplement what we know about you with information that is available to the public. This allows us to better understand your interests, preferences, and level of potential engagement and/or donation, so that we can contact you in the most appropriate way and to ensure that we do not send you unwanted communications. The information we collect and process about you from publicly-available sources may include demographic information associated with your postcode or your address and an estimate of your age. We may collect this information ourselves or through third-party service providers. For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.
Where we have identified that you may have the capacity or affinity to support Change Nigeria Project at a higher level, we may use the information we hold about you to identify connections between you and our existing circle of key supporters. We may review other information about you that is available to the public through internet searches, social networks, such as LinkedIn, subscription services, news archives or public databases (e.g., Companies House, the electoral, political and property registers), such as information about corporate directorships, shareholdings, published biographic information, employment and earnings, philanthropic interests and networks, charitable giving history and motivations and relevant media coverage, so that we can engage with you in a more personalised way.
DO WE PROCESS ‘SENSITIVE’ PERSONAL INFORMATION?
Under data protection law, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs, and political opinions (‘sensitive personal data’). In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so, such as where we need this information to ensure that we provide appropriate facilities or support to enable you to participate in an athletic event like a marathon.
HOW DO WE USE YOUR INFORMATION?
We may use your information in a number of ways, including:
In particular, we may contact you for marketing purposes by email or text message if you have agreed to be contacted in this manner. We may also send you service communications via email or text, for example where you place an order for goods or services on our website, or you have made a donation by text.
If you have provided us with your postal address or telephone number, we may send you information about our work or other communications of the kinds described above by direct mail or contact you by telephone unless you have told us that you would prefer not to hear from us in this way. We provide information about how you can change your marketing preferences below.
HOW WILL WE COMBINE AND ANALYSE THE INFORMATION WE COLLECT ABOUT YOU?
In our Supporter Promise, we have committed to communicating with you using an approach that is right for you. This means that we carefully manage the communications we send you to ensure that we are contacting you in the most appropriate way and that we are not sending you unwanted communications. In order to do this, we may combine the information that we collect about you and analyse what we know about your interests, preferences and level of potential engagement or donation. We may also use statistical analysis to analyse this data and understand the likelihood that you will be interested in or responsive to a campaign or message. We may use third party service providers to assist us in this process. For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.
Where we have identified that you have the capacity or affinity to support Change Nigeria Project at a higher level, we may collect additional information about you (see ‘What information do we collect?’) and combine and analyse that information in a profile of you that will assist us in engaging with you in a more personalised way.
You can opt out of your data being combined and analysed for marketing purposes by contacting our Supporter Care Team or our Data Protection Officer as described below. However, this may mean that you stop receiving marketing communications from us more generally, as we will be unable to determine their relevance to you.
In accordance with our legal and regulatory obligations and our internal policies and procedures, we may also use personal information to carry out due diligence on potential or actual donors. If you opt out of analysis of your data for due diligence purposes, we may not be able to accept donations from you.
HOW WILL WE DISCLOSE THE INFORMATION WE HAVE COLLECTED TO OUTSIDE PARTIES?
Change Nigeria Project may provide your information to our service providers. Subject to your communication preferences and our internal policies and procedures, this would include providing your information to third parties that work with us to deliver on our charitable purposes, and other entities that act as fundraisers for Change Nigeria Project, sell Change Nigeria Project branded products or provide Change Nigeria Project with marketing information and services.
Where you have agreed to receive email or SMS marketing communications from us, we may provide your email address or mobile phone number in an encrypted format to social media companies, such as Facebook, Instagram, Twitter or YouTube, or to digital advertising networks that are providing services to us by displaying our advertising to you on those social media platforms and other websites, as well as identifying audiences with interests similar to yours. You can opt out of your data being used to display advertising to you by contacting our Supporter Care Team or our Data Protection Officer as described below. However, this will not prevent our advertisements being shown to you on a randomised basis or based on cookie data and may mean that you stop receiving marketing communications from us more generally.
We enter into contracts with all of these service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.
We will never sell your details. We will only share your details with third parties (who are not service providers working at our direction) as indicated in this Policy or if you have consented or we have another legal basis to do so. We will not make cold telephone calls to members of the general public for individual support and, therefore, will not purchase your data in order to do so.
We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect Change Nigeria Project, for example in cases of suspected fraud or defamation, or in order to comply with any other applicable legal obligation.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary.
Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk. However, any payment card details (such as credit or debit cards) we receive on our website are passed securely to our payment processing provider according to the Payment Card Industry Security Standards.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will keep and delete your information according to our internal policies and will keep it no longer than reasonably necessary for the purposes for which we hold it, taking into account relevant legal and regulatory retention requirements (e.g. tax or health and safety requirements) and operational considerations.
HOW CAN YOU CHANGE YOUR MARKETING PREFERENCES OR UPDATE THE INFORMATION WE HOLD ABOUT YOU?
In our Supporter Promise, we pledge to make it clear and easy for you to choose how you hear from us. If you do not wish us to use your personal data for marketing purposes as outlined above, you can use the relevant box on the print or online form on which we collect your data or you can follow instructions provided in a print or poster advertisement or in a TV advert to indicate your preference.
You can also change any of your marketing preferences at any time (including telling us that you don’t want us to contact you for marketing purposes) by:
If you have indicated that you do not wish to be contacted for marketing purposes, we will maintain your details on a suppression list to help ensure that we do not continue to contact you for marketing purposes. However, we may still need to contact you for administrative purposes, including (but not limited to):
Similarly, if your contact details have changed or you think any information we have about you is incorrect or incomplete, you can always update or correct the information we hold about you by contacting us through our Supporter Care team as explained above.
WHAT OTHER DATA PROTECTION RIGHTS DO YOU HAVE?
Under UK data protection law, you have certain rights over personal information that we hold about you. These rights are summarised below. Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances.
You can assert your rights, raise a concern, or make a complaint about how we process your personal data by contacting our Data Protection Officer or our Supporter Care team. It will assist us, if you explain your request or concern and describe the personal information you are referencing as specifically as possible. In order to action your request, we may need to request further information or request that you provide proof of identity.
Your rights in relation to our processing of your personal information, include:
If you are not happy with how we have handled your request or complaint, you can contact the Office of the Information Commissioner, which oversees the protection of personal data in the UK.
Alternatively, you may choose to contact the Information Commissioner directly about your complaint, regardless of whether you have raised it with us first.
WHY ARE WE ALLOWED TO PROCESS YOUR PERSONAL INFORMATION?
Generally, our processing of your personal information as described in this policy is allowed by these laws based on one or more lawful grounds, including:
For example, we rely on legitimate interests for activities such as sending marketing communications by post or telephone unless you have told us that you would prefer not to hear from us in this way, contacting you as a representative of an organisation about charity partnerships or in order to organise an event, and analysing your interaction with us to improve our internal business processes.
In any event, where we are relying on legitimate interests to process your personal information, we will consider any potential impact on you (positive or negative), your rights under data protection laws, and will not use your personal information for activities where the impact on you overrides the legitimate interests in the processing.
Where we process sensitive personal data (as mentioned above), we will make sure that we only do so in accordance with one of the additional lawful grounds for processing that type of data, such as where we have your explicit consent or you have made that information manifestly public.
JOB AND VOLUNTEER APPLICANTS AND CURRENT AND FORMER EMPLOYEES
You will receive a separate Privacy Statement from us when providing information for these purposes.
YOUR CREDIT OR DEBIT CARD INFORMATION
If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your card details securely to our payment processing partner as part of the payment process. We do this in accordance with the Payment Card Industry Security Standard (PDF download), and don’t store the details on our website or databases.
When you register with us, you are stating that you are 18 years of age or over. You agree that any information you provide to us about yourself upon registration or at any time is true.
Emails aren’t always secure, and they may be intercepted or changed after they’ve been sent. Change Nigeria Project doesn’t accept liability if this happens. The contents of emails reflect their author’s views and not necessarily those of Change Nigeria Project.
Please do not send Change Nigeria Project any financial data through email.
The information in emails is confidential, so if you’ve received one by mistake, please delete it without copying, using, or telling anyone about its contents.
COOKIES AND HOW WE USE THEM
1. Strictly necessary cookies: These cookies are essential for the user to move around the website and to use its features, e.g. shopping baskets and e-billing.
2. Performance cookies: These cookies collect information about how the user makes use of the site, e.g. which pages the user visits most. These cookies do not collect information that identifies the user.
3. Functionality cookies: These cookies remember choices made by or attributes of the user and enhance the features and content you experience during your visit to our website, e.g. language, appeals visited or user’s location. This cookie is also used to remember a user’s preferences for a font size, or customisable parts of a web page.
4. Targeting or advertising cookies: These cookies collect information about the users’ browsing habits. This may also include your use of social media sites, e.g. Facebook, etc. or how you interact with our website which then shows you relevant content elsewhere on the internet. NB. These may also be used to choose the advertisements that are displayed to you on our website and other websites.
WHAT INFORMATION DO WE COLLECT USING COOKIES?
Although not through cookies, we do measure the success of the emails we send – so we know what subject lines and stories people liked the most. We receive this information anonymously; we don’t share this information.
WEBSITE STATISTICS ANALYTICS, TESTING AND PERSONALISATION
Because we are in a transition period, our website currently uses three types of web analytics services:
1. Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which (as discussed above) are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
You can always opt-out of Google Analytics cookies by Google’s opt-out tool.
You can always opt-out of Adobe Analytics cookies by Adobe’s opt-out tool.
You can always opt out of Decibel Insight cookies by visiting their website.
OTHER THIRD-PARTY COOKIES
You may notice some other cookies that are not related to Change Nigeria Project website whilst visiting www.changenigeriaproject.co.uk. Some of our pages contain embedded content such as YouTube video, Twitter feed, or Facebook likes and share, and you may receive cookies delivered from these websites. Change Nigeria Project does not govern the publication of third-party cookies. To understand more about their cookies and privacy statements, please visit the relevant sites.
Some of our cookies will remind you about our work and how you can help after you have left the website. These are the targeting/advertising cookies we use. It is a useful tool for us to keep public awareness of our campaigns and how they can be supported.
If you do not want cookies to be stored on your PC it is possible to disable this function without affecting your navigation around the site.
CHANGING YOUR COOKIE PREFRENCES
The “Help” menu in the toolbar of most web browsers will tell you how to change your browser’s cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. Below is some helpful guidance about how to make these changes.
HOW TO DISABLE COOKIES
If you are using Microsoft Internet Explorer and you wish to block Change Nigeria Project’s website cookies, you can perform the following:
1. On your browser tools menu, select ‘Internet Options’
2. Click on the ‘Privacy’ tab and then on the ‘Sites’ button
3. Type into the ‘Address of website’ field: www.changenigeriaproject.co.uk
5. Click on the ‘Block’ button
6. Click on the OK button
Find out more information about blocking or deleting cookies using Microsoft Internet Explorer.
7. Other browsers:
Last updated: August 2018