Privacy policy.

Tottenham Conservative Association ( “TCA” ) is committed to protecting the privacy of those with whom it interacts, and TCA recognises the need to respect and protect information that is collected or disclosed to us (called “personal data”, explained below). This Privacy Notice is intended to tell you how we use your personal data and is in a layered format to give you enough detail to give you the information you need at a glance , with the option of following a link if you want to find out more. If you still can’t find the information you need, you can contact TCA by using the details set out in section 1 below.

We seek to ensure that all personal information is handled in accordance with the UK Data Protection Act 1998 and the EU General Data Protection Regulation. If you have questions about this policy, you can contact us at the email provided in section 1.

 

1. Who are we?

Tottenham Conservative Association. (“ we ” / “ us ” )

TCA is the controller of your personal data (as defined below).

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the following details:

Angelos Tsangarides

Unit 8

349C High Rd

Wood Green

N22 8JA

Website:   https://www.tottenhamconservatives.co.uk/ (“ our website “ )

Email: conservatives4tottenham@gmail.com

2. What is personal data, and which personal data do we collect about you?

For the purposes of this Privacy Notice “ personal data ” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier ( e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, economic, cultural or social identity. When we combine other information ( i.e. information that does not, on its own, identify you) with personal data, we treat the combined information as personal data.

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

·        Identity and Contact Data includes first name, last name and title, address and email address.

·        Financial Data

·        Technical Data includes data about your use of our website and online services, such as your IP address, login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. 

·        Promotional Data includes your preferences in receiving promotional material from us.

·        Political Opinions are special categories of personal data which we may collect about you. We would only collect this personal data if there is a clear reason for doing so and will only do so with your explicit consent.

We do not collect other Sensitive Data about you. This includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

3. How is your personal data collected?

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

1.      Personal Information that you provide directly . You may give us your Identity and Contact Data, Promotional Data, Financial Data and Special Categories of Data by filling in forms on our website, when you donate, become a member or volunteer with us, if you request information about us and our events, if you choose to receive promotional material from us, attend one of our events or when you correspond with us by email, phone or otherwise.

2.      Automated technologies or interactions.

3.      Third parties or publicly available sources . We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from third party analytics providers, such as Google Analytics.

4. How do we use your information?

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

·        Where we have obtained your consent.

·        Where we need to perform the contract we are about to enter into or have entered into with you.

·        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. The legitimate interests we rely on are set out next to each purpose below.

·        Where we need to comply with a legal obligation. 

If we rely on consent to process any of your personal data, you may withdraw this consent at any time.

Purposes for which we will use your personal data

We may use the personal data that we collect for the following purposes. For each purpose, we describe the legal bases we rely on to justify such use of your personal data.

Purpose or Activity	Type of Data	Legal Basis
To provide you with information about us that you specifically request from us	(a) Identity and Contact	(a) Necessary for our legitimate interests in promoting TCA and providing you with the information you have specifically requested
Provide you with promotional information related to events and donation opportunities which we feel may be of interest to you.	(a) Identity and Contact (b) Technical (c) Promotional	(a) Consent.
To enable you to make a donation to TCA	(a) Identity and Contact (b) Financial	(a) Performance of a contract with you (b) Necessary for our legitimate interests in enabling our supporters to make donations
To enable us to achieve our campaigning purposes.	(a) Identity and Contact	Necessary for our legitimate interests in ensuring the successful and effective operation of TCA
Analysis purposes – for assessment and analysis of our supporters and to create promotional plans	(a) Identity and Contact	Necessary for our legitimate interests to study how our clients use our services, to develop our services and to inform our marketing strategy
For security purposes and to administer our website – to maintain and enhance the website and to ensure that content from it is presented in the most effective manner for you and your computer, and to enhance the user experience;	(a) Identity and Contact (b) Technical	(a) Necessary for our legitimate interests in running LFP, to ensure the security of our systems, to assist us in the provision of administration and IT services, network security and to prevent fraud (b) Necessary to comply with a legal obligation
Internal record purposes – for monitoring and record keeping including maintaining our accounts, complying with good practice and for other administrative, operational and security reasons	(a) Identity and Contact (b) Financial (c) Promotional	(a) Necessary for our legitimate interests in running TCA efficiently and successfully and in order to keep our records updated (b) Necessary to comply with a legal obligation
To enable us to make correspondence relevant, we may collate a profile on you based on your interactions with TCA. You may opt out of profiling at any time by contacting us using the details at the bottom of this policy (see section 10 below)	(a) Identity and Contact (b) Financial	Necessary for our legitimate interests in running effective campaigns and securing donations
To prevent and detect crime, fraud or corruption and to meet our legal, regulatory and ethical responsibilities	(a) Identity and Contact (b) Technical (c) Services	Necessary to comply with our legal obligations

Promotional Material

We may use your personal data to provide you with email notifications and other communications by email, on the basis that we have obtained your specific opt-in consent to do so. For further information on this, see the ‘Your Choices’ section of this Privacy Notice.

Combining personal data

We may combine the personal data that we collect from you to the extent permitted by applicable law. For example, we may combine various different databases that contain your personal data to allow us to provide better support services and more personalised content (such as marketing). This is also referred to in the section, ‘Purposes for which we will use your personal data.’

Change of purpose

Where we need to use your personal data for another reason other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. To whom do we disclose your information?

We will only disclose your information to the following entities:

1.      Service Providers
We use third party service providers to help us to administer certain activities and services on our behalf. Included within this are organisations which help us process donations, as well as IT and cloud services, website hosting and support services, marketing services, analytics providers and payment facilitators. We may share personal data about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions.

2.      Third parties when required by law
We will disclose your personal data to comply with applicable law or to respond to valid legal process, including from regulators, law enforcement or other government agencies (in which case such agencies or regulators will be acting as controllers as well); to protect the users of the website (e.g. to prevent spam or attempts to defraud them); to operate and maintain the security of the website (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights or property.

3.      Other Parties At Your Direction
We may share personal data about you with third parties when you request such sharing.

6. What do we do to keep your personal data secure?

We have put in place appropriate physical and technical measures to safeguard your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. When we use service providers to assist us in processing your personal data, we have written contracts in place with such service provider which means that they may not do anything with your personal data unless we have instructed them to do it.

However, please note that although we take appropriate steps to protect your personal data, no website or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your personal data.

International Transfer of Data

The personal data that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area (“ EEA “ ), including but not limited to the United States of America or in any other country where our service providers maintain facilities.

By using the website and/or providing us with your personal data, you acknowledge that we will collect, transfer, store and process your information outside the EEA. We will take all steps reasonably necessary to ensure that your personal data is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located.

Where we transfer your personal data outside the EEA to third parties, we will ensure that appropriate transfer agreements and mechanisms are in place to help ensure that our third party service providers provide an adequate level of protection to your personal data such as the EU’s Standard Contractual Clauses .  We will only transfer your personal data outside the EEA in accordance with applicable laws or where you have given us your consent to do so.

7. Data Retention – How long will we store/keep your personal data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

When your personal data is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.

In some circumstances you can ask us to delete your personal data (see section 8 below).

8. Accessing your personal data and other rights you have

We will collect, store and process your personal data in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have the following rights in relation to your personal data:

1.      Subject Access – you have the right to request details of the personal data which we hold about you and copies of such personal data.

2.      Right to Withdraw Consent – where you have consented to our processing of your personal data, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 1.

3.      Data Portability – you may, in certain circumstances, request us to port ( i.e. transmit) your personal data directly to another organisation.

4.      Rectification – we want to ensure that the personal data about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate personal data about you.

5.      Erasure (‘right to be forgotten’) – you have the right to have your personal data ‘erased’ in certain specified situations.

6.      Restriction of processing – you have the right in certain specified situations to require us to stop processing your personal data.

7.      Object to processing – you have the right to object to specific types of processing of your personal data, such as, where we are processing your personal data for the purposes of direct marketing.

8.      Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing.

Enforcing your rights

If you wish to enforce any of your rights under applicable data protection laws, then please contact us by using the details set out at section 1 above. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may, if permitted to do so by applicable data protection laws, charge a reasonable fee for dealing with your request which we will notify to you.

Complaints

If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner’s Office ( www.ico.gov.uk ) which is the data protection regulator in the UK, which is where TCA is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.

9. Cookies

What are cookies?

We may use cookies on our website. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. Cookies are assigned to and stored in a user’s internet browser on a temporary (for the duration of the online session only) or persistent basis (cookie stays on the computer after the internet browser or device has been closed).

Cookies collect and store information about a user’s preferences, product usage and content viewed which allows for us to provide users with an enhanced and customised experience when engaging with the website.

We use cookies on our website in the following ways to:

1.      track users as they navigate the website

2.      improve the website’s usability

3.      analyse the use of the website

4.      administer the website

5.      prevent fraud and improve the security of the website

6.      personalise the website for each user.

We currently use the following cookies:

·       _GRECAPTCHA

·       cookieNotificationHasBeenSeen

·       rc :: a

·       rc :: b

·       rc :: c

·       _ sp_ id .#

·       _ sp_ ses .#

·       dm_last_page_view

·       dm_last_visit

·       dm_this_page_view

·       dm_timezone_offset

·       dm_total_visits

·        fbss l s_

·       i /jot

·       RichHistory

·       snowplowOutQueue_snowplow_cf

·       fbsr _

·       modernizr

10. Your Choices ( e.g. promotional material or otherwise)

When you request information on or from the website, or otherwise communicate with us, we may use your personal data (such as your contact details ( e.g. name, address, email address, telephone number)) to send you our promotional correspondence by email. When we process your personal data for promotional purposes, we do so on the basis that we have obtained your consent to use your personal data for these purposes.

We may also use your personal data to personalise and to target more effectively our campaigning material to ensure, to the extent possible, that any such correspondence is relevant to you. This is designed for the purpose of increasing donations to our campaign, and to ensure a better experience for you as part of TCA. 

We do not share your personal data for marketing purposes with third party companies.

You may opt-out of receiving promotional material from us at any time. If you wish to do so, please click “Unsubscribe” from any marketing or promotional email you receive from us.

11. Changes to this Privacy Notice

It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.

We will provide notice to you if these changes are material and, where required by applicable law, we will seek your consent. We will provide this notice by email or by posting notice of the changes on our website.

Latest update 29 January 2023