PRIVACY POLICY

EMBRACE PRIVACY POLICY

This privacy statement applies to Embrace the Middle East and its subsidiary Embrace the Middle East Trading, a private company limited by guarantee and registered in England and Wales with company number 00901022 whose registered offices are at the Old Library Building, Queen Victoria Road, High Wycombe, HP11 1BG.

The websites referred to in this statement are embraceme.org and shop.embraceme.org 

Embrace the Middle East and our trading subsidiary hold and process personal details in accordance with the Data Protection Act 2018.

If you have any questions about this policy or how your data is handled, please contact our supporter experience team.

Data protection

We take data protection very seriously.

As you use our website, get in touch with us, or take part in our events and activities, we collect information. This deepens our understanding of what you are interested in and helps us to improve the quality and relevance of all of our communications with you.

We will never share your information with another organisation for their own marketing purposes and we will never sell your information for any reason whatsoever.

We do, however, need to collect and use your personal information for carefully considered and legitimate business purposes. This policy sets out what data we collect, how we will use it, what the legal basis for this is, and outlines what your rights are in respect of your personal data.

Purposes

The main reason we will use your personal information will be to help us effectively carry out our charitable activities. We will use your personal information to provide you with the services, products or information you have requested, for administration purposes and to further our charitable aims, which may include fundraising activities.

We may use your personal information to contact you about how you can support the work of Embrace the Middle East through prayer, campaigning, volunteering, awareness raising, shopping and through providing financial support. We may also send you information on how to engage your church congregation through prayer, campaigning and fundraising.

  1. Fundraising, campaigning and marketing: We have a range of fundraising and marketing activities that are designed to raise money and promote the aims and objectives of the charity. We use a range of marketing activities and channels such as direct marketing (post and digital), advertising (print, broadcast and digital) and public relations to tell you about the difference you can make through prayer, campaigning, giving and shopping. This includes sending out resources that may include magazines, appeals, catalogues and other information. We may also ask if you are able and prepared to Gift Aid any of your donations.
     

  2. Management of volunteers: If you are one of our valued volunteers, we may need to use your personal information to manage your volunteering activities, deliver training, involve and update you on our work, and to ensure your safety. This may include sending you newsletters or information about our fundraising appeals so that you are best equipped to perform your role and advise the public about our work.
     

  3. Retail activities: Through our catalogue and webshop we offer individuals the chance to purchase both commercial and charity products. If you purchase items through our Trading subsidiary, we may use your personal information for the marketing of similar products in future. We will also use your information to process the purchase of any items and for the recovery of Gift Aid.

  4. Analysis, targeting and segmentation: We are committed to communicating with you as effectively and efficiently as possible. Our aim is to provide you with information about our work and to provide you with opportunities to support the work of our Christian partners as they seek to transform the lives of the most vulnerable in the Middle East. In order to do this we will make use of information you have given us and your interactions with us to help us predict your interests and tailor and personalise our communications in the future.

  5. Profiling: In some limited circumstances, we may combine the personal information you have given us with information available in the public domain to create a profile of your interests and preferences where they are relevant to your potential engagement with us. When building such a profile we may make use of additional information about you, including geo-demographic information and measures of affluence. This information is taken from publicly available sources, for example from public registers, such as listed Directorships, typical earnings in a geographical area, information from Companies House, the electoral roll, press reports, media and social media posts. We may use third party suppliers to undertake these activities on our behalf and share your information with them to the extent required. You can opt-out of your personal information being used for profiling or analysis by emailing us or calling 01494 897950.
     

  6. Due diligence research: Embrace the Middle East trustees have a duty to ensure that there is no reputational or financial risk to accepting a donation or other kind of support. We may therefore use publicly available sources to carry out due diligence on potential donors to ensure that we are fundraising within the law. For more information on this please see our policy on accepting or refusing donations. This is available by emailing us or calling 01494 897950.

Lawful processing

Under General Data Protection Regulations (GDPR) we need a lawful basis to collect and use your personal data. There are three purposes allowed under GDPR which we rely on to legally process your data.

  • Information is processed on the basis of an individual’s consent.

  • Information is processed in line with a contractual relationship.

  • Information is processed on it being a legitimate interest for us to do so.

Consent

We will always ask for your consent to send you marketing by email, SMS and by telephone for the purpose of marketing.

Where you give us consent to process your data we will always keep a clear record of how and when this consent was obtained, and you can withdraw this consent for all channels and activities at any time by emailing us or calling 01494 897950.

Contractual relationships

The vast majority of relationships with our supporters and beneficiaries are voluntary and not contractual. This purpose primarily relates to how we process the data that we hold in relation to our staff, and in some circumstances, our volunteers.

Legitimate interests

The law allows personal data to be legally collected and used by an organisation if it is necessary for a legitimate business interest of the organisation - as long as its use is fair and balanced and does not unduly impact the rights of the individual concerned.

What are our legitimate interests?

Governance:

  • Transfers between Embrace the Middle East and our wholly-owned subsidiary Embrace the Middle East Trading.

  • Reporting criminal acts and compliance with the legal instructions of law enforcement agencies.

  • Internal and external audit for financial or regulatory compliance purpose.

  • Statutory reporting.

Publicity and income generation:

  • Conventional direct marketing by direct mail and other forms or marketing, publicity or advertisement.

  • Unsolicited commercial or non-commercial messages, including campaigns, income generation or charitable fundraising.

  • Unsolicited communications to churches and other organisations, for example schools, with whom we work closely in order to publicise our appeals and campaigns.

  • Personalisation to tailor and enhance the supporter experience in our digital and postal communications.

  • Analysis, targeting and segmentation to develop fundraising strategy and improve communication efficiency.

  • Processing for research purposes.

  • Profiling, including the use of publicly available information.

Operational management:

  • Employee and volunteer recording and monitoring for recruitment, safety, performance management or workforce planning purposes.

  • Provision and administration of staff benefits such as pensions.

  • Physical security, IT and network security.

  • Maintenance of suppression lists.

  • Processing for historical, research or statistical purposes.


Financial management and control

  • Processing of financial transactions and maintaining financial controls.

  • Prevention of fraud, misuse of services, or money laundering.

  • Enforcement of legal claims.

Purely administrative purposes

  • Responding to any solicited enquiry from any of our stakeholders.

  • Delivery of requested products, resources or information packs.

  • Administration of direct debits and other existing financial transactions.

  • Administration of Gift Aid.

  • Providing 'thank you' communications and receipts.

  • Maintaining 'do not contact' lists.

When we use your personal information, we will always consider if it is fair and balanced to do so and whether it would be within your reasonable expectations that we would use your data in this way.

What information we collect

The types of personal information collected might include:

  • name

  • date of birth

  • email address

  • postal address

  • telephone number

  • mobile phone number

  • direct debit details

  • donation or shopping history 

  • your opinions about a product, service or an issue

  • communications to and from yourself

  • Gift Aid declarations

Sensitive personal information

Under data protection law, certain categories of personal information are recognised as sensitive, including health information, race, religious beliefs, and political opinions (‘sensitive personal data’). In limited cases, we may collect sensitive personal data about you which might include links to churches or professional clerical title eg Rev.

Credit and debit card information

If you use your credit or debit card to donate to us, or buy something 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 Data Security Standard.

Where does this information come from?
The vast majority of personal data we hold is given to us directly by our supporters, customers and volunteers in the course of them interacting with our services, websites, or fundraising activities. We may also receive your personal information when you fundraise for Embrace the Middle East through third party services such as Just Giving or Virgin Money Giving.

How long will we keep your data?

We will keep personal data in line with our data retention policy. The length of time each category of data will be retained will vary on how long we need to process it, the reason it is collected, and in line with any statutory requirements.

After this point the data will either be deleted or rendered anonymous. We will retain your details as long as is necessary to communicate effectively with you and to ensure that, in the event that you kindly include us in your will, your legacy is correctly administered and that we can communicate effectively with your family.

Who will we share your data with?

As explained above, we will never sell your personal information and will never share it with another organisation for their own marketing purposes. However, there are a number of legitimate situations where we may share your information with third parties whom we have contracted to fulfil specific services for us. This will include organisations such as mail fulfilment houses and email broadcasters who will send out our marketing materials on our behalf. In all of these situations we ensure that we always have a written contractual agreement in place that will ensure that those organisations can only use the data provided for the specific purposes we direct them to do and that they have in place strict security requirements in order to protect your personal information.

How to change the way we communicate with you

If you would like to change the way we communicate with you please contact us either via post: Supporter Experience Team, Embrace the Middle East, Old Library Building, Queen Victoria Road, High Wycombe, HP11 1BG, email us. or telephone +44 (0) 1494 897950.

If you have previously chosen to receive email communications from Embrace the Middle East but no longer wish to receive email communications, please click the unsubscribe link at the bottom of any of our emails to be removed from our list.

Changing your personal details

If your personal details change, please help us to keep your information up to date by notifying us through one of the routes listed above.

Links

Our website may include links to websites run by other organisations. Embrace the Middle East is not responsible for the privacy practices of other organisations’ websites so you should read their privacy policies carefully.

Data security

We take data protection seriously, we have a Data Protection Policy and an Acceptable Use Policy in place. The two policies are aligned with the new General Data Protection Regulation Law (GDPR) and the Data Protection Act 2018 and both govern how we securely store and use the data we hold.

Cookies

We use cookies in order to give you a better online experience. A cookie is a small file downloaded on to your computer when you access a website. Cookies allow a website to recognise users when they return to a site by opening doors to different content or services. Like a key, a cookie itself does not contain information, but when it is read by your browser it can help a website improve the service delivered. For more information about cookies, please see www.allaboutcookies.org.

What to do if you are not happy?

Our complaints policy can be found here.

Changes to this privacy statement

From time to time, we will make changes to this statement to keep it up to date and relevant. Please make sure you check regularly to see what's changed.