Privacy Policy

This Policy explains when and why we at Safer Tourism Foundation (“STF”) collect personal information how we use it, the conditions under which we may disclose it to others and how we keep it secure. It only applies to information we collect about you when you visit our website, whenever you contact us, volunteer with us or become involved with us in any way. We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.

If you have any questions regarding this Policy and our privacy practices, you can contact [email protected] and we will respond as soon as possible.

Contents

  1. Introduction – who we are
  2. What information will STF collect about me?
  3. How will my information be used?
  4. When will STF Contact me?
  5. Will I be contacted for fundraising and marketing purposes?
  6. What is STF’s legal basis for processing my personal data?
  7. Will STF share my personal information with anyone else?
  8. What about Financial information?
  9. External Links
  10. Offensive and inappropriate content on STF’s website
  11. How long will STF keep my information?
  12. Security of your information
  13. Can I find out what personal information STF holds about me & my access rights?
  14. How to make a complaint?

1. Introduction – who we are

STF is the Data Controller and is committed to protecting the rights of individuals in line with the General Data Protection Regulation (GDPR), which replaces the Data Protection Act 1998. We want our services to be safe for our audience. This Policy relates to the data which is processed by STF only.

STF is a registered charity in England and Wales (no 1168944) and a company limited by guarantee (no 09670319) with its registered address at Astolat, Coniers Way, Guildford, Surrey GU4 7HL.

2. What information will STF collect about me and why?

The type of information we collect and how we use it depends on why you are providing it and when we collect it from you.

We may collect information when:

  • you visit our website;
  • you contact us through social media platforms;
  • you make a donation;
  • your data is passed to us by third parties to enable us to use it for statistical purposes in order to further our charitable objects – whether to better inform holiday-makers of dangers and risks or lobby travel companies and others in order to effect practical changes to improve the health and safety of travellers;
  • you subscribe or respond to mailings; and
  • you request information.

Please see ‘How will my information used’ below for information as to why we hold your information and data and how it might be used.

The personal information we collect might include:

  • your name, address and email address and contact preferences;
  • telephone and mobile telephone numbers;
  • bank account and credit/debit card details;
  • whether you are a UK tax payer (so that we can claim Gift Aid);
  • information about injuries, health and safety and other issues suffered by travellers;
  • details of your visit to our website including your IP address and information regarding what pages are accessed and when; and
  • other information you input on our website.

If you make a donation online or make a purchase from STF, your card information is not held by us; it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions, as explained below.

3. How will my information be used?

We will mainly use the data we collect to:

  • build an evidence base from which to understand the root causes of preventable injuries, illnesses and deaths occurring to people travelling abroad, including from carbon monoxide poisoning
  • we may share statistical evidence (which will ordinarily be anonymised or pseudonymised) with third parties in order to effect practical changes to improve the health and safety of travellers;
  • process a donation that you have made;
  • process orders that you have submitted;
  • to carry out our obligations arising from any contracts entered into by you and us;
  • seek your views or comments on the services we provide and on our work more generally;
  • notify you of changes to our services;
  • in the case of photographs, to promote and advertise the work of STF but always with the prior approval of those identifiable in the photograph;
  • provide a personalised service to you when you visit our websites. This includes the use of cookies if you agree to their use;
  • send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other fundraising events and newsletters; or
  • process a job application.

4. When will STF Contact me?

We will contact you:

  • in relation to any service, activity or online content you have signed up for in order to ensure that STF can deliver the service;
  • in relation to any correspondence we receive from you or any comment or complaint you make about STF’s services;
  • in relation to any personalised services you are using;
  • to invite you to participate in surveys about STF services (participation is always voluntary);
  • to update you on any material changes to STF’s privacy policies and practices; and
  • for fundraising and communication purposes, as set out in below section.

5. Will I be contacted for fundraising and marketing purposes?

STF will only send you fundraising and communication emails and posts or contact you on STF’s platforms where you have agreed to this or we have a legitimate interest to do so under data protection law.

We offer a newsletter, to let you know about STF. From time to time we may also contact you to ask your views on issues affecting STF.

You can change your preferences at any time by contacting us by email: [email protected] or telephone on 07773 716887.

6. What is STF’s legal basis for processing my personal data?

The General Data Protection Regulation requires us to process personal data fairly, lawfully and transparently.

We will therefore be clear with you about how we will use your data and why we are entitled to do so.

When we collect and use your personal information, we will make sure this is only done in accordance with at least one of the legal grounds available to us under data protection law.

One of these is where we have obtained your specific consent to use your information for a previously notified purpose, such as to send you email/text marketing or to provide you with a product, service or information at your request.

Another is where we have a legal obligation to use or disclose information about you – for instance, where we are ordered by a court or regulatory authority or we are legally required to hold donor transaction details for Gift Aid or accounting/tax purposes.

In certain instances, we may collect and use personal information where this is necessary in STF’s legitimate interest; this includes being able to:

  • send direct marketing material to supporters by post or contacting them by telephone for fundraising purposes;
  • conduct research to better understand who our supporters are and better target our fundraising activity;
  • monitor who we deal with to protect our charity against fraud, money laundering and other risks;
  • maintain and administer our supporter database and systems.

Where appropriate, we balance our legitimate interests against your rights as an individual and make sure we only use personal information in a way or for a purpose that you would reasonably expect in accordance with this Policy and that does not intrude on your privacy or previously expressed marketing preferences.

Where we process sensitive personal data, we will make sure that we only do so in accordance with one of the additional lawful grounds for processing such as where we have your explicit consent, you have made that information manifestly public or where we do so for statistical purposes. When we do this, we will tell you what sensitive personal data we are collecting and why unless it would require disproportionate effort or data protection law exemptions apply.

We always handle your personal data securely and minimise its use, and your interests are not overridden by using your personal information for these purposes

Our Data Protection Lead is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data, and can be contacted at [email protected].

7. Will STF share my personal information with anyone else?

  • We use statistical data in order to better inform holiday-makers of dangers and risks or lobby travel companies and others in order to effect practical changes to improve the health and safety of travellers.
  • We will not sell or pass your information to third parties other than in the circumstances set out in this Policy.
  • We will not share your information with third parties for marketing purposes.
  • In other cases we will not disclose any of your personal data except in accordance with this Policy, when we have your permission, or where we are required or entitled to do so by law.

We may allow our suppliers to access and use your personal data to allow them to perform services on our behalf (e.g. payment processing). In these circumstances we will not give these organisations any rights to use your personal information except to provide services to us and in accordance with our instructions.

We may need to transfer your personal data to suppliers based in the US or other countries outside of the European Economic Area (EEA) to allow them to perform services on our behalf (such as when we use our the automated marketing platform we use which is based in the USA). In doing so, your data may be stored or otherwise processed outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are in place:

  • the country has been deemed to provide an adequate level of protection for personal data by the European Commission;
  • a specific contract which is approved by the European Commission and gives personal data the same protection it has in EEA, has been entered into with the supplier; or

Where we use service providers based in the USA, it is accredited under the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the USA.

8. External Links

Although this website only seeks to include high quality, safe and relevant external links, users should always adopt a policy of caution before clicking any external web links mentioned throughout this website.

We cannot guarantee or verify the contents of any externally linked website despite best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.

9. Offensive and inappropriate content on STF’s website

If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on or to STF website or otherwise engage in any disruptive behaviour STF may remove such content.

Where STF reasonably believes that you are or may be in breach of any applicable laws, for example on hate speech, STF may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. STF would only do so in circumstances where such disclosure is permitted under applicable laws, including GDPR.

10. How long will STF keep my information?

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. STF is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on our individual business and charitable needs. Please contact our Data Protection Lead if you would like further detail on the retention periods contained in our Data Retention Policy.

11. Security of your information

When you give us personal information, we take steps to ensure that it’s treated securely. Any sensitive information provided by you is encrypted and protected. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

12. Can I find out what personal information STF holds about me & my access rights?

Under GDPR you have the right to:

  • request a copy of the personal information STF holds about you
  • be informed about processing of your infomration,
  • access information we hold about you
  • rectificy your data
  • erasure
  • restrict processing
  • data portability
  • object
  • in relation to automated decision making and profiling.

If you wish to do so, please send a description of the information you want to see and proof of your identity in writing to our Data Protection Lead: [email protected]

How to make a complaint

If you are unhappy with the way in which your personal data has been processed by us, you may in the first instance contact STF’s Data Protection Lead using the contact details above.

If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: –

Information Commissioner’s Office
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

www.ico.org.uk

Review of this Policy

We keep this Policy under regular review. This Policy was last updated in June 2018.

Published on 09/06/18

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