Last updated 17 April 2019
The Wellbeing Economy Alliance/WEAll (“we” or “us”) values your privacy. This Privacy Notice explains who we are, how we collect, share and use Personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to Personal Information that we collect through our website at https://www.wellbeingeconomy.org/ (“the Site”), We will never sell or share your Personal Information outside of what you allow through normal use of the Site.
If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
This Privacy Notice (the “Notice”) applies only to the Site. If you click on a link to another website from the Site, the Notice will not apply to the information collected on that website. WEAll has no control over such third party websites and will not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to have been caused by or in connection with the use of or reliance on any content, advertising, products, or other materials on or available from such websites, nor from any information that you provide to such websites or that such websites collect from you.
The Notice applies to the collection and use of Personal Information, which means any information relating to an identified or identifiable natural person, including, but not limited to, an individual’s name, address, email address, telephone number, Social Security Number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information (“Personal Information”).
Personal Information does not include “aggregate” information, which is data collected about the use of the Site or about a group or category of services or users, from which individual identities or other Personal Information has been removed and cannot be identified. The Notice does not restrict or limit WEAll’s collection and use of aggregate information.
In some circumstances we are a data processor following the instructions of our partners, the data controllers, for example when you take action through the WEAll website for a petition or other action organized by a third party partner, our partner will be the data controller and, information you submit through the Site as part of the form filling process will be made available to the data controller directly. WEAll has no ability to control, and shall have no responsibility for, how such data controller uses your information. We will not review, share, distribute or reference any Personal Information except as provided in our agreement with our partners, or as may be required by law.
INFORMATION WE COLLECT
Information that you provide voluntarily when you use the Site
You may voluntarily provide Personal Information to WEAll when you:
Sign up to join WEAll Citizens
Enter your username/password
Make a donation (e.g. bank account details)
Fill out a form
Send us an email
Fill out a survey
Leave comments/participate in discussion pages
Sign up to host an event
Conduct searches on the Site
Sign up to receive email alerts/updates
What personal information will WEAll use?
|Personal information we may process||Our reasons for processing||Our legitimate interests|
|Name||Our legitimate interests||To keep in contact with supporters|
|Address and contact details|
|Sex/gender||Administering our business|
|Information about personal circumstances|
|Bank account details||Fundraising for our charitable purpose|
We share limited information with our service providers HiveBrite, 1&1, Mailchimp & WordPress who help us send you our communications. We do not allow these organisations to use your data for their own purposes, and we will not share your data with other organisations for their own marketing purposes.
If you disclose any information in comment boards, discussion pages or elsewhere on the Site, it becomes public information and can be read, collected, or used by others. Please exercise caution when disclosing any Personal Information, and refrain from publicly disclosing direct contact information such as your mailing address, phone number, or email address.
Online Petitions, Events, and Forms
When you sign an online petition, register for an event, or fill out a form, that action is public information. WEAll may make the action, your name, city, country, and any comments you offer in connection with the action publicly available.
Information automatically collected when you visit and use the Site
When you visit the Site, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (“EEA”), this information is considered Personal Information under applicable data protection laws.
Information that we collect from other sources
WEAll may access information about you from third-party sources and platforms. This information may include:
- If you access third-party social networking sites (such as Facebook, Twitter or Google Plus) through the Site, and contact lists for those services
- Unique identifiers, including mobile device identification numbers, that can identify the physical location of such devices in accordance with applicable law
HOW WE USE COLLECTED INFORMATION
We may use the collected information in various ways to provide our services, including:
To send users email or other electronic communications
To allow our third party partners who have created actions to send users who have filled out those actions email or other electronic communications
To track users’ involvements in community discussions and use of the Site
To fulfill users’ requests for services and information
For internal analytics and to improve the quality and relevance of the Site to our visitors
To maintain and improve the accuracy of the records we hold about you
Any other purposes disclosed to you at the time the information is collected or pursuant to your consent
HOW WE SHARE COLLECTED INFORMATION
WEAll will only make Personal Information about users available to third parties as described below:
- To give third party partners who have shared actions through the Site the information of users who have filled out those actions. We are the data processor for our partners (who are data controllers) and as such we are merely following their instructions on how we process your Personal Information. Our processing is handled in accordance with the terms in place with our partners.
- To trusted third party service providers including vendors, consultants, and volunteers employed to perform Site-related services, including database management, web hosting, maintenance services, analytics, data processing, geolocation, technical support services, credit card processing, security services, and email and text message distribution. These third parties have access to users’ Personal Information only to perform these tasks on our behalf, and on the condition that they will maintain the confidentiality of all Personal Information.
- When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal process or respond to lawful requests, claims or legal authorities, including lawful subpoenas, warrants, or court orders.
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent.
We may share aggregate information with third parties to help us develop content or services.
To customize your experience on this Site and to simplify the Site’s registration process, we provide you with the opportunity to access or interact with third-party services, such as Facebook, Twitter, and Google Plus. When you connect to the Site through these third-party services, we may share Personal Information about you with these third-party service providers and they may share Personal Information about you with us.
We may use data that we receive from these third-party service providers to:
- Enhance and personalize your experience on the Site (e.g., import your profile picture)
TRANSFERS OUTSIDE THE EEA
We, or carefully selected third parties that we contract with, may send personal data to countries outside the European Economic Area (‘EEA’). If and when this occurs, there will be protections in place to ensure the recipient protects the data to the same standard as the EEA. The protections include:
- transferring to a non-EEA country with privacy laws that give the same protection as the EEA.
- putting in place a contract with the recipient that means they must protect personal data to the same standards as the EEA.
- transfer personal data to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for personal data sent between the US and EU countries which makes sure standards are similar to what is used within the EEA.
COOKIES AND OTHER SIMILAR TRACKING TECHNOLOGIES
As is standard practice on many websites, we may set and access cookies, web beacons, Flash cookies, and other similar tracking technologies (collectively, “Cookies”) on your computer. Cookies are small amounts of information stored in files within your computer’s browser. For further information about Cookies we use, why, and how you can control cookies please see our Cookies Notice.
Collection of Information by Third Parties
Please note that third party ad networks, advertising agencies, advertisers, and audience segment providers and other companies (e.g. Google DoubleClick, Yahoo Tremor and 24/7 RealMedia) may also set and access Cookies on your computer when you visit the Site.
YOUR CHOICES REGARDING THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION
To reduce the amount of Personal Information that WEAll collects from you and limit its use, you can take one or more of the following steps:
- Opt-out of receiving emails from WEAll, by clicking the unsubscribe link in emails you receive from us
- Opt-out of receiving emails from our third party partners for whom you have filled out actions, by clicking the unsubscribe link in emails you receive from them, or by not opting in to email communication in the first place when you fill out one of their forms
- Opt-out of allowing WEAll or our partners to collect your geographic location by changing the location settings on your mobile device
- Opt-out of linking your activity on the Site to your social networking sites, such as Facebook, Twitter, and Google Plus by not creating an account with one of those services and creating an account directly with us instead
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
As described in this notice, if you are using the Site through one of our partners (e.g. the organisation organising an action) then we are the processor of your Personal Information and our partner is the data controller. In such cases, if you want to exercise any data protection rights above or have questions or concerns about how your personal information is handled by WEAll as a processor on behalf of our partners, you should contact the relevant partner that has contracted with WEAll, and refer to their separate privacy notices.
Because WEAll has a limited ability to access Personal Information our partners submit to the Site or that you submit to the partner on the Site, if you wish to make your request directly to WEAll, please provide the name of the partner who submitted your Personal Information to the Site or who you submitted Personal Information to on the Site. We will refer your request to that partner, and will support them as needed in responding to your request within a reasonable timeframe.
If you are a visitor from the EEA, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting the partner who you wish to delete your personal information, or by contacting us at firstname.lastname@example.org with the name of the partner and we will forward your request to them, as described above.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting the partner who controls your personal information, or by contacting us at email@example.com with the name of the partner and we will forward your request to them, as described above.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. For UK users, this is the Information Commissioner’s Office. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, to provide our partners with a service they have requested, or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it at our partner’s request or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Where we our processing Personal Information on behalf of one of our partners are we are a data processor we will process Personal Information as instructed by our partner.
The period for which the personal data will be processed
We will retain personal data securely and only in line with how long it is necessary to keep for the purposes or for a legitimate and lawful reason.
Our typical retention periods are as follows:
|Trustee / Volunteer personnel documents||
Deleted 7 years after the appointment ends
|Job / volunteer applicants (unsuccessful)||Deleted 6 months after the post applied for closing date (or 6 months for speculative applications)|
|Supporter contact details||
Deleted 7 years after the enrolment
|Photographs and case studies||7 years after the termination or expiry of the grant agreement|
Some personal data may be retained for longer where it is in our legitimate interest to do so, such as to protect and defend our legal rights; or for research, archiving or statistical purposes. Individuals can request that other information relating to them be erased and we will deal with such requests in accordance with the law.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (FOR VISITORS FROM THE EEA)
If you are a visitor from the EEA, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
For all the data where WEALL is acting as processor, our partner makes that determination.
Where WEAll is acting as a controller, we will normally collect Personal Information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
If we collect and use your Personal Information in reliance on our legitimate interests, this interest will normally be to operate the Site and service, communicating with you as necessary to provide our services, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Contact Us” heading below.
CHILDREN UNDER AGE 13
We encourage parents to monitor their children’s Internet usage and to caution them about the dangers of sharing Personal Information on the Internet. Although we welcome children under age 13 to visit the Site with parental supervision, children under age 13 should not visit the site on their own and should not submit any Personal Information to the Site. We do not knowingly collect Personal Information from children under age 13. If we learn that we have collected any Personal Information from a child under age 13 without verifiable parental consent, we will delete that information from our database as soon as possible.
CHANGES TO THE PRIVACY NOTICE
WEAll may update the Notice at any time to reflect changes in our practices. If we modify the Notice, we will place a prominent notice on the Site and/or send a notice to the primary email address provided in your registration with the Site or take other appropriate measures to inform you, consistent with the significance of the changes we make. As part of any modification of the Notice, we will update the “last revised” date at the top of this Notice.