Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2    The platform enables you to select whether to ask for agreement to continue using cookies on a user’s first visit to the site.

1.3    This privacy policy was last updated on 27 03 2018

  1. Credit

2.1    This document was created using a template from SEQ Legal (http://www.seqlegal.com).

  1. How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

3.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services

3.3    We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services

3.4    We may process your information included in your personal profile on our website ("profile data").  The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.

3.5    We may process your personal data that are provided in the course of the use of our services ("service data"). The source of the service data is you or your employer. The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

3.6    We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent

3.7    We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.8    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent

3.9    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.10  We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.11  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.12  Please do not supply any other person's personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes

4.3    We may disclose personal data to our suppliers or subcontractors insofar as reasonably necessary for the purposes of obtaining professional advice and maintaining our website

4.4    Financial transactions relating to our website and services are handled by our payment services providers, Stripe and GoCardless. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/gb/privacy and https://gocardless.com/legal/privacy/ 

4.5    Your data may also be available to our website provider to enable us and them to carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

  1. Your data will be made available to our website provider
  2. The data that may be available to them include any of the data we collect as described in section 3 above.
  3. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
  4. They will store your data for a maximum of 5 years.
  5. This processing does not affect your rights under sections 10 or 16 of this privacy policy

4.6    We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

4.7    In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    We and our other group companies have offices and facilities in Ethiopia. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to Ethiopia will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission

5.3    The hosting facilities for our website are situated in the UK. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries.

5.4    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  1. Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain and delete your personal data as follows:

(a)    Personal Data will be retained for 5 years, at the end of which period it will be deleted from our systems.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of personal data will be determined based on legitimate interest.

6.5    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We may notify you of changes to this policy by email.

  1. Your rights

8.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2    We may withhold personal information that you request to the extent permitted by law.

8.3    You may instruct us at any time not to process your personal information for marketing purposes.

8.4    In practice, you will expressly agree in advance to our use of your personal information for marketing purposes.

  1. Third party websites

9.1    Our website includes hyperlinks to, and details of, third party websites.

9.2 This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them.  If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data

9..3 We operate a number of social media pages (including Facebook, Twitter, You Tube and Instagram).  Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information.  Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

  1. Personal data of children

10.1  Our website and services are targeted at persons over the age of 16.

10.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

  1. Updating information

11.1  Please let us know if the personal information that we hold about you needs to be corrected or updated.

  1. Acting as a data processor

12.1  In respect of your data, we do not act as a data controller; instead, we act as a data processor.

12.2  Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

  1. About cookies

13.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that we use

14.1  We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website

(b)    status - we use cookies to help us to determine if you are logged into our website. (Cookies used for this purpose are ASP.NET_SessionId and MemberLoggedIn)

(c)    personalisation - we use cookies to store information about your preferences and to personalise the website for you

 (d)   security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally

(e)    advertising - we use cookies to help us to display advertisements that will be relevant to you

(f)    analysis - we use cookies to help us to analyse the use and performance of our website and services

(g)    cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (Cookies used for this purpose are cc_cookie_accept)

  1. Cookies used by our service providers

15.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

15.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy

15.3  We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

  1. Managing cookies

16.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16.2  Blocking all cookies will have a negative impact upon the usability of many websites.

16.3  If you block cookies, you will not be able to use all the features on our website.

  1. Our details

17.1  This website is owned and operated by Project Harar.

17.2  We are registered in [England and Wales] under registration number 1094272, and our registered office is at Pyramid House, 956 High Road, London N12 9RX.

17.3  Our principal place of business is at 4a Park End, London, NW3 2SE.

17.4  You can contact us:

(a)    by post, using the postal address given above;

(b)    by telephone, on the contact number published on our website from time to time; or

(d)    by email, using [email protected]

  1. Data protection officer

18.1  Our data protection officer's contact details are: Mimi St-John Austen, [email protected]

  1. Complaints

19.1  If you have a complaint about us, or the treatment of your data, you can contact the Charity Commission. The Charity Commission is the independent watchdog for charities.  You can make a complaint about a charity on their website at www.charity-commission.gov.uk.

19.2  If you've got a complaint about our fundraising activities you can also complain to the Fundraising Standards Board (FRSB).  To find out whether a charity is an FRSB member and how to go about making a complaint, go to the FSRB public website at www.givewithconfidence.org.uk]

This processing does not affect your rights as detailed in this privacy policy