This is the public privacy and data protection notice for all public users of Shubbak’s services and assets.
Purpose of Policy
We are committed to protecting your personal information and being transparent about what information we hold about you.
Using personal information allows us to develop a better understanding of and relationship with our users, patrons, employees, trustees, funders, stakeholders and contractors; and in turn to provide relevant and timely information about the work that we do.
The purpose of this policy is to give you a clear explanation about how we collect and use the information we collect from you and to meet our duties of transparency.
We gather, store and use information concerning the protection of personal information, in accordance with the following applicable laws:
- The Privacy and Electronic Communications (EC Directive) Regulations 2003
- General Data Protection Regulation 2016/679 (European Union regulation)
- Data Protection Act 2018
This policy explains:
- What information we may collect about you
- How we may use that information
- In what situations we may disclose your details to third parties
- Information about how we keep your personal information secure, how we maintain it and your rights to be able to access it
Your Rights Relating To Your Personal Data
Users have the right to request a copy of the information that we hold about them. If you would like a copy of some or all of your personal information, you can email or write to us – our contact details are provided on our website. We may make a small charge for this service. We want to make sure that personal information is accurate and up to date. Users can ask us to correct or remove information which they think is inaccurate. By law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
Legal Basis For Processing Your Data
There are three bases under which we may process your data:
If you enter into a contract with us, in order to perform this contract, we need to process and store your data.
Legitimate business interests
In certain situations, we collect and process your personal details for purposes that are in our legitimate organisational interests. However, we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
With your explicit consent
For any situations where the two bases above are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.
Users can choose to subscribe to Shubbak’s mailing list to receive news about our programme, festivals, offers, fundraising activities and related events. By providing us with you contact details, you are giving us explicit consent to contact you. If you subscribe to our mailing list concerning a particular event or subject, then we use our legitimate organisational interest as the legal basis for any continued communications by email.
Users can unsubscribe from the mailing list and future communications by following the links at the bottom of every email we send out via MailChimp. If we have contacted users in the past and they have explicitly told us that they don’t want to receive marketing communications from us, we will keep their name and address on a list of people we don’t contact. If they would prefer for their information to be deleted from that list, they can let us know using the contact details on our website.
We may also use your postal address and/or phone number, if you have provided these, for us to keep in touch with you. We will always get explicit consent from you to use those details at the time that you provide them to us.
Emails that we send or receive may be retained as a record of contact and email addresses stored for future use in accordance with our record retention schedule. If we need to email sensitive or confidential information to you, we will perform checks to verify the correct email address and may take additional security measures.
Other Processing Activities
We also process personal information in the following ways that are within our legitimate organisational interests:
- We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
- We may analyse data we hold about you in order to identify and prevent fraud.
- In order to improve our website, we may analyse information about how you use it and the content and ads that you interact with.
- We may use profiling techniques or third-party wealth screening and insight companies to provide us with information about you that will help us to communicate in a relevant way with you, in particular when we are approaching you about potential philanthropic support. Such information is compiled using publicly available data about you.
In all of the above cases we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy.
Shubbak will not pass personal data to third parties for marketing, sales or any other commercial purposes without prior explicit consent. There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
- To our own service providers who process data on our behalf and on our instructions. In these cases, we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.
- Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
We may process personal information using web services hosted outside the European Economic Area, but only where a data processing agreement is in place that complies with obligations equivalent to those of the Data Protection Act.
In addition to the Personal Data that we collect directly from you, we may also collect certain of your Personal Data from third party sources such as credit reference agencies, social media sites and analytics providers for identity verification, behavioural and technical data which may or may not already be publicly available.
Cookies are small text files that are automatically placed onto your computer device by some websites that you visit. They are widely used to allow a website to function as well to provide website operators with information on how the site is being used. You can learn more about all the cookies we use on our website below.
- To ensure the website works.
- To monitor website performance and help us make improvements in the future.
- To tailor our marketing, and use tools such as Google AdWords to communicate more effectively through web advertising.
Our cookies help us to:
- To ensure the website works.
- Remember your settings during and between visits.
- Improve the speed/security of the site.
- Allow you to share pages with social networks like Facebook.
- Continuously improve our website for you.
- Make our marketing more efficient.
- Collect any sensitive information.
- Pass personally identifiable data to third parties.
- Collect any personally identifiable information.
Cookies set by www.shubbak.co.uk:
Anonymous visitor statistic cookies
Third party cookies
Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube or Vimeo video and SoundCloud audio file. While we have made an effort to minimise their use, some third party services embedded within this website set their own cookies. These are known as third party cookies because they are not set by our website. We have no control over the cookies that are set by third party services. Disabling these cookies will likely break the functions offered by these third parties.
Social website cookies
So you can easily “Like” or share our content on social networks like Facebook and Twitter, we have included sharing buttons on our site. Cookies are set by the sites below. The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.
Cookies are widely used in online advertising. Neither us, advertisers or our advertising partners can gain personally identifiable information from these cookies. We only work with advertising partners who work to accepted privacy standards such as http://www.youronlinechoices.com/goodpractice. You can opt out of almost all advertising cookies here.
It is easy to manage cookies by adjusting your browser settings. For more information and how to opt out, visit any of the following sites.
To opt out of being tracked by by Google Analytics across our website please get the Google Analytics Opt-out Browser add-on.
Third Party Links
Maintaining Your Personal Information
We store your personal information indefinitely, such that for any subsequent purchases you make we are able to link them back to a single unique record that we hold for you on our system.
To determine this retention period, we considered 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 the applicable legal requirements, which includes financial returns and Gift Aid declaration timescales.
If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging in to your account through our website. Alternatively please use the contact details at the end of this policy.
Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
How We Keep Your Personal Data Safe
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
Please send any queries or questions to firstname.lastname@example.org or address them to Shubbak, c/o Arab British Centre, 1, Gough Square, London EC4A 3DE.
Last updated May 2020.