Privacy Notice - Veterans Housing Scotland

VETERANS HOUSING SCOTLAND WEBSITE PRIVACY NOTICE

1 INTRODUCTION

Veterans Housing Scotland respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data, your privacy rights, and how the law protects you when you:

visit our website (regardless of where you visit it from);
make a donation to us (regardless of the form in which this donation is made);
take part in any fundraising activity or event for our benefit;
organise a fundraising activity or event for our benefit.

In this privacy notice, "Data Protection Legislation" means all applicable legislation related to the protection of individuals regarding processing personal data, including the Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 and the Privacy and Electronic Communication Regulations 2003.

2 IMPORTANT INFORMATION AND WHO WE ARE

2.1 Purpose of this privacy notice

This privacy notice aims to give you information on how Veterans Housing Scotland collects and processes your personal data through your use of this website, including any data you may provide through this website; when you donate to us. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you to be fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

2.2 Controller

Veterans Housing Scotland, which is a Scottish Charity has its registered office at 525 Ferry Road, Edinburgh EH5 2FF with Registered Charity Number SC003174, is the controller and responsible for your personal data (referred to as "Veterans Housing Scotland", "we", "us" or "our" in this privacy notice). Our Company Registration no is 10795.

3 INFORMATION THAT WE COLLECT FROM YOU

3.1 What is personal data?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).

3.2 What personal data do we collect from you?

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:

Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
Contact Data includes billing address, delivery address, email address and telephone numbers;
Financial Data: includes bank account and payment card detail (if provided when donating);
Donation Data: includes details about donations made by you and other details of products, tickets and services you have purchased from us;
Technical Data: includes internet protocol (IP) address, your login data, 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;
Usage Data: includes information about how you use our website, products and services and your attendance at events;
Equal Opportunity Data: includes information on your gender, sexual orientation, ethnicity, age, religion, and any disability that you may have; and
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preference.

4 HOW IS YOUR PERSONAL DATA COLLECTED?

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

Direct interactions: You may give us your Identity Data, Contact Data, Financial Data and Donation Data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
- donate to us through our website;
- fill in any forms on our website;
- request marketing to be sent to you;
- register to receive or download information, newsletters or other documentation;
- -give us some feedback.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see paragraph 8 below for more information.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- Identity, Contact, Financial, Donation and Marketing and Communications Data from any third-party donation or purchasing site (e.g. JustGiving, Virgin Giving, BTDonate or PayPal).
- Technical Data from analytics providers, advertising networks, and search information providers.

5 HOW WE USE YOUR PERSONAL DATA

5.1 What processing grounds do we rely on?

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 you have provided us with your consent to send you marketing communications;
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 (for example, undertaking analysis and research to improve our website user experience); and
We need to comply with a legal or regulatory obligation (for example, equal opportunity monitoring).

Please note that we may process your personal information without your knowledge or consent. This is required or permitted by law. Generally, we do not rely on consent as a legal basis for processing your personal data other than concerning sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

We may process your personal data for more than one lawful ground depending on the specific purpose of using your data. Please contact us by emailing admin@vhscot.org.uk if you need details about the specific legal basis we rely on to process your personal data.

5.2 How do we use your information?

We use your information:

to enable us to supply you with the services and information which you have requested;
to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
for all other purposes consistent with the proper performance of our operations and business;
to contact you for your views on our products and services; and
to help us with understanding more about how our website and services are used.

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason. That reason is compatible with the original purpose. Suppose we need to use your personal information for an unrelated purpose. In that case, we will explain the legal basis, which allows us to do so.

6 DISCLOSURE OF YOUR INFORMATION

The information you provide to us will be treated as confidential. However, we may disclose your information to other third parties who act for us for the purposes set out in this privacy policy or for purposes approved by you, including to suppliers who provide marketing, financial, cloud computing and ticketing services. 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.

7 DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

We may also hold your personal information for longer where it is necessary to do so to manage any active or potential legal proceedings, resolve or defend claims, and make any necessary remediation payments.

8 COOKIES

We use cookies to track your use of our website www.vhscot.org.uk and to provide tailored marketing messages when you visit our websites, and to enhance your use of our website. When you first visit our website, a 'cookies banner' will direct you to this privacy policy. If you continue to browse without disabling our cookies, you consent to our use of cookies as described here.

A "cookie" is a piece of software that attaches to the hard drive of your computer and remembers information about the configuration of your computer. You can choose not to accept cookies from our website. We use a number of cookies on our website, including cookies provided by Google Analytics and Facebook.

We use the following categories of cookies on our websites:

Strictly necessary: These cookies are essential for our websites' features to work (for example, when you make payments to us for purchasing goods or services). These cookies do not record identifiable personal information. We do not need your consent to place these cookies on your device. Without these cookies, some services you have asked for cannot be provided.
Performance: These cookies are used to collect anonymous information about how you use our websites. This information is used to help us improve our websites and understand how effective our adverts are. In some cases, we use trusted third parties to collect this information for us. However, they only use the information for the purposes explained.
Functionality: These cookies are used to provide services or remember settings to enhance your visit, for example, text size or other preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites.
Targeting and Advertising: These cookies are used by trusted third parties to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of the advertising campaign. Information contained in these cookies is anonymous and doesn't include your personal information. To find out more about cookies used for targeting and advertising, follow www.youronlinechoices.com and www.networkadvertising.org or contact us for further details on the trusted third parties we use.
Managing our cookies: If you would prefer to restrict, block or delete cookies from our third-party advertisers and us, or any other website, you can use your browser to do this. Each browser is different, so check the "Help" menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies, we cannot guarantee our websites' performance. Some features may not work as expected. Please contact us for details of the specific cookies which we use on our website. For further information on cookies and how to disable them, please refer to www.allaboutcookies.org.

9 MARKETING

9.1 Marketing by us

We may use your Identity, Contact, Financial, Donation and Marketing and Communications Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have given us your express consent to receive marketing communications. Where you have given us your express consent, we will send marketing communications to you on behalf of our third-party sponsors and partners.

9.2 Third-party marketing

We are committed to providing you with information on products and offers which are relevant to you. If you have consented to receive marketing, we will use your email address to promote our adverts to you on Facebook, Google and other social media channels. These adverts may appear on your Facebook newsfeed if you have a Facebook account linked to an email address that has been provided to us. Suppose you no longer wish to receive the advertisements detailed above. In that case, you can unsubscribe at any time by contacting us at admin@vhscot.org.uk. Please note; you may receive adverts from us which are not connected to having provided us with your email address. An example of this may be when Facebook uses users' information in accordance with its privacy and cookies policies to advertise. We cannot accept responsibility for any such advertisements.

9.3 Opting out

You can ask third parties or us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. You may still receive notifications from us for nonmarketing purposes, such as service messages providing important announcements where you opt-out of receiving these marketing messages.

10 THIRD PARTY WEBSITES

Because we want your site experience to be as informative and helpful as possible, we may provide links to websites operated by third parties ("Third Party Websites"). Please be aware that we do not control such Third-Party Websites. Such Third-Party Websites may send their own cookies to users; otherwise, they collect data or solicit personal information. We assume no responsibility for the information gathering practices of Third Party Websites that you can access through our Site. We encourage you to review each Third Party Website's privacy policy before disclosing any personally identifiable information.

11 SECURITY

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 have put in place procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so. In some circumstances, we may 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 policy to you. Please be aware that the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to restrict unauthorised access. All credit/debit card data taken through our website is encrypted in accordance with industry standards, including PCI-DSS.

12 YOUR RIGHTS

Under Data Protection Legislation, you are entitled to exercise the following rights over your personal data:

Right to object: You can object to our processing of your information.
Access to your personal information: You can request access to a copy of your information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can request access free of charge.
Right to withdraw consent: If you have given us your consent to use your information to send you marketing emails, you can withdraw your consent at any time or by clicking the "unsubscribe" link in any marketing email which you receive.
Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
Erasure: You can ask us to delete your information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used electronic form so that it can be easily transferred.
Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
Make a complaint: You can complain about how we have used your information by contacting us or to a supervisory authority - for the UK, this is the Information Commissioner's Office, at https://ico.org.uk/. If you would like to exercise any of your rights above, please contact us by email at admin@vhscot.co.uk

13 CHANGES TO THIS POLICY

We may amend this privacy policy from time to time. If we make any substantial changes, we will notify you by posting a prominent notice on our website or by email. Historic versions can be obtained by contacting us.

14 YOUR DUTY TO INFORM 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.

15 CONTACT US

If you have any questions about this privacy notice, including any requests to exercise your legal rights or making a complaint to us about how we have used your personal data, please contact us by emailing admin@vhscot.org.uk or by writing to us at "Veterans Housing Scotland, 525 Ferry Road, Edinburgh, EH5 2FF"

Last updated March 2021