Justin Edinburgh 3 Foundation Privacy Policy

1. INTRODUCTION

Justin Edinburgh 3 Foundation takes your privacy seriously. This privacy policy explains how Justin Edinburgh 3 Foundation (Hereafter referred to as “JE3 Foundation”, “we”, and “us”) uses personal data that you provide or which JE3 Foundation collects and holds about you when you use its official websites and/or other services. JE3 Foundation is the data controller of this information for the purposes of this policy. JE3 Foundation’s Data Protection Officer is John Eagleton, who is contactable via the details provided below.

JE3 Foundation’s websites and services include:

• The official JE3 Foundation website at http://www.je3foundation.com;

• The official JE3 Foundation social media pages on Facebook, Twitter, Instagram, LinkedIn (together the “JE3 Foundation Official Websites”); and

• The official JE3 Foundation telephone line, of which the number is 07583146744.

2. ABOUT US

JE3 Foundation is a registered charity (no. 1993256). Our registered address is:

1 Moulsham Street

Chelmsford

Essex

CM2 0HR

3. LEGAL NOTICE

This policy has been prepared in line with the data protection laws applicable in the United Kingdom, including the Data Protection Act 2018, the General Data Protection Regulation (GDPR) and any subsequent amendment or legislation passed to enact GDPR into UK Law.

4. CONTACTING US ABOUT THIS PRIVACY POLICY

If you have any questions or concerns about this policy or about your personal data, please contact our Data Protection Officer by emailing DPO@je3foundation.org.

5. THE TYPES OF PERSONAL DATA WE HOLD

Information we hold about you may include any one or more of the following types of data:

Account information: When you register to use, purchase or engage with any of JE3

Foundation’s goods and/or services, the minimum information we will usually ask you

to provide is your name, email address, country of residence, telephone number and

postal address. We may also ask you for additional information depending on the

nature of our interaction with you.

Transactional information: When you purchase goods or services from the JE3

Foundation Official Websites, we will keep a record of your transaction, including what

you purchased and when, and any information you provide to us to fulfil the

transaction. This may include your name, billing information, postal address and

telephone number. We will not keep payment card information, except for the last four

digits of your payment card number which we keep in case there are any payment

disputes or in the event that we need to issue a refund. We will ensure that, when

handling any information about you relating to a transaction, we comply with the

applicable regulations of the Payment Card Industry. When you register to take part in

events or fundraise for us we will keep a record of your name, age, email address,

postal address, and telephone number.

Where you purchase services on behalf of a third party (for example, where you book onto an event or other service provided by JE3 Foundation) we will usually take details of the participants attending the event or other service, in addition to the transactional information described above. This is in order to administer the provision properly to the participant and use your details for the other purposes described in this policy.

Information you provide to us in response to a survey: We may occasionally contact you to ask for your feedback on JE3 Foundation goods and/or services or goods or services provided by a third party affiliate on our behalf (for example, goods, services, or experiences provided by a partner) so that we can implement improvements and make them more relevant.

Information you provide to us in response to a job advertisement, where you contact us about a potential role at JE3 Foundation or where you volunteer with JE3 Foundation: We may advertise open positions on the News section of our website at www.je3foundation.com/news.

Information from other companies: We may use publicly available postal address lists and the edited electoral roll to ensure that the information we hold about you is accurate or we may use this information, together with general market research information (for example, demographic information), to add to and enhance our database.

Online usage information: If you use JE3 Foundation Official Websites we may collect your browser type, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page. Online usage information may be linked to a unique identifier but we do not link online usage information to named individuals. In order to collect online usage information we use cookies and other similar technologies. A complete list of the cookies we use can be found in our Cookies Policy.

Information you provide when communicating by email, telephone, or social media: On occasion, you may provide personal information via email as it relates to JE3 Foundation goods, services or activities, including but not limited to: name, email address, country of residence, telephone number, date of birth and postal address. We do not collect billing or payment card information by email or social media.

Donations and Gift Aid: When you fundraise or donate to JE3 Foundation (including where you make any one-off donations) we will keep a record of your title, name, email address, postal address, and telephone number. If you are a UK tax payer and donate to JE3 Foundation through a paper form or through an online platform such as Just Giving or PayPal Donate and opt for JE3 Foundation to reclaim the tax on the donation, in addition to the above, JE3 Foundation will also collect your tax status.

Information you provide to us in order to take part in an activity: In order to take part in JE3 Foundation’s activities you will need to provide data such as name, date of birth, address, ethnicity, sex, and relevant medical information.

In most cases, you are not obliged to provide any personal data to us, but in some cases we may not be able to provide goods or services to you unless you provide certain minimum information. By way of example only, where you intend to make a purchase from JE3 Foundation, we may need to obtain and process certain information about you in order to enter into and perform the contract of sale with you.

6. THE PURPOSES FOR WHICH WE USE YOUR INFORMATION

The legal basis under which JE3 Foundation will process your personal data is one or more of the following:

• To allow us to enter into and/or perform our contract with you;

• To enable us to comply with legal obligations;

• To pursue legitimate interests of our own or those of third parties (provided that your interests and fundamental rights do not override those interests); and/or

• With your consent. For the avoidance of doubt, we will only use your information for marketing purposes (where such consent is necessary) where we have your consent

Further details of how we will process your personal information are listed in the table below.

Purpose/activity

Personal data types

Basis

Contract Performance: JE3 Foundation may use account information and transactional information data, as necessary, to carry out or perform any contract which you may have entered into with us, including contracts for the purchase of goods, courses and any other services, merchandise and other products. We also use this information to communicate with you and handle your enquiries regarding these contracts. If you purchase JE3 Foundation goods, products or services for another person (for example, a team of employees or a family member) we may ask you for their personal information and we will use this to provide the services you have ordered. Please ensure that you have their permission for us to process this data before providing it to JE3 Foundation.

Your name, billing information, email address, postal address and telephone number. We will not keep payment card information, except for the last four digits of your payment card number which we keep in case there are any payment disputes or we need to issue a refund (contact details and card payment details). In some cases, subject to the nature of the service provided, we may also request date of birth, medical information and/or sex.

To allow us to enter into and/or perform a contract with you

Legal Obligations: JE3 Foundation retains records of all of its financial transactions with you in order to comply with its legal obligations to maintain adequate accounting records. JE3 Foundation may use (and disclose) the information it holds about you in order to comply with any investigative demand, court order, or a request for cooperation from a law enforcement or other government agency.

Your name, billing information, email address, postal address and telephone number. We will not keep payment card information, except for the last four digits of your payment card number

To enable us to comply with legal obligations

Recruitment/Volunteering: If you apply for a job, register to be a volunteer or apply for a work experience placement with JE3 Foundation we may use your information for the purposes of recruitment and selection, corresponding with you and for equal opportunities monitoring.

Name, email address, telephone number, previous work, education, referees and answers relevant to the role
Results of disclosure checks from the Disclosure and Barring Service (DBS) if you are working with children under 16 or adults receiving health or personal care

To pursue legitimate
interests of our own or those of third parties (provided that your interests and fundamental rights do not override those interests);

With your
consent. We will only use your information for marketing purposes (where such consent is necessary) where we have your consent.

• Legal obligations (Safeguarding and Vulnerable Groups Act 2006)

Marketing where it is in our legitimate interest: We may market to you with news, competitions and offers from JE3 Foundation, its affiliates and its official sponsors and partners which we think may be of interest to you, and conduct related surveys, or analytics, where it is in our legitimate interest, and where your consent is not necessary. This can apply to individuals (e.g. analytics) but also to contacting data subjects who work for businesses.

Your name, email address, postal address, date of birth, and telephone number.

To pursue legitimate
interests of our own or those of third parties

(provided that your interests and fundamental rights do not override those interests);

and/or

With your consent. We will only use your information for marketing purposes
(where such consent is

necessary) where we have your consent.

Marketing with your consent where it is necessary: If you have consented to it (where consent is necessary) JE3 Foundation may contact you electronically with news and offers from JE3 Foundation, its affiliates, our sponsors which we think may be of interest to you. You have the right to withdraw your consent at any time, by emailing our Data Protection Officer at DPO@je3foundation.com.

Your name, email address, postal address and telephone number.

With your consent. We will only use your information for marketing purposes (where such consent is necessary) where we have your consent.

Other Purposes: JE3 Foundation will analyse information it holds about you to identify trends and preferences about its customers and to get a more detailed and informed picture of how its customers are using JE3 Foundation’s products and services. We do this to make improvements to our products/services and the function of the JE3 Foundation Official Websites. JE3 Foundation may also use the information it holds about you if required to protect the rights, property, or safety of JE3 Foundation, customers or others.

Name, email address, postal address, telephone number, medical  information, types of adjustments required and details of why the adjustment is required.

To pursue legitimate interests of our own or those of third parties (provided that your interests and fundamental rights do not override those interests)

To make reasonable service adjustments to make sure that you can access our services safely if you have a disability or health condition

• Name, email address, telephone number, medical information, type of adjustment required and details of why the adjustment is required.

• Legal obligation (Equality Act 2010)

• With your explicit consent

To produce case studies: which can be included in publications and other forms of publicity

• Name, date of birth, photographs, details of services.

With your consent. We will only use your information for marketing purposes (where such consent is necessary) where we have your consent.

Special categories of personal data: JE3 Foundation may occasionally collect anonymous special categories of personal data on you for the purposes of better understanding our supporter/customers/stakeholder base, identifying ways to improve communication and to maintain JE3 Foundation’s commitment to equality, diversity and inclusion.

You can opt out of JE3 Foundation processing your special categories of personal data at anytime by either opting out of any communication sent to you or notifying the Data Protection Officer at DPO@je3foundation.org.

• Racial and ethnic origin, date of birth, sex, gender, disability, religious or philosophical beliefs, data concerning medical information, health and/or your states of physical or mental health, sexual orientation.

With your consent. We will only use your information (where such consent is necessary) where we have your consent.

7. AUTOMATED DECISION-MAKING

JE3 Foundation will not carry out any automated decision-making using information it holds about you. If this changes, we will update this policy and notify you accordingly.

8. DISCLOSURE OF YOUR INFORMATION WITH THIRD PARTIES

We may share your personal information with third parties as part of our service to you. The list below shows who we may share information with and for what purposes:

Affiliates: Information held by JE3 Foundation may be used by affiliates of JE3

Foundation for the purposes set out in this policy, where you have consented to this.

JE3 Foundation does not currently have any affiliates with regards to shared ownership

or related properties, sponsors or partners as it applies to the sharing of data. Should

this change, we will update this policy and notify you accordingly.

Sponsors and partners: JE3 Foundation does not share your personal data with our

sponsors and partners, but we may: (i) share aggregate/anonymised information which

is based on this information with existing and potential sponsors and partners; and (ii) if

you have consented to the same, send you information about the products and

services of our partners and sponsors in our marketing communications.

Suppliers and sub-contractors: JE3 Foundation may share your information with

suppliers and sub-contractors from time-to-time in order that they can process it on

JE3 Foundation’s behalf for the purposes set out in this privacy policy. However, where

we do so we will put in place suitable measures in order to protect your information.

These third parties may include (but may not be limited to): (i) IT service providers (such

as hosting providers); (ii) mailing houses or document storage companies; (iii) delivery

services; (v) payment processing companies; and/or (vi) e-commerce platform

providers.

Funders: JE3 Foundation may share your information with funders who have provided

finance to JE3 Foundation in order to deliver services to the local community or to run

a particular programme.

Disclosures for legal reasons: JE3 Foundation may disclose the information it

holds about you to those persons that have a reasonable need to know such

information, if it believes in good faith that this is necessary: (i) to establish, exercise or

enforce its legal rights, including contractual rights; (ii) to defend itself against a legal

claim; (iii) report a crime or prevent a crime; (iv) to prevent harm to any individual or any

property (including intellectual property, for example if you misuse images or videos or

any other content JE3 Foundation makes available to you); (iv) to satisfy our statutory

and/or regulatory obligations relating to safeguarding; or (v) to prevent fraud (for

example, payment card fraud) or for credit risk reduction.

Business transfer: If JE3 Foundation sells or buys any business or assets, your

personal data may be disclosed to the prospective seller or buyer of such business or

assets so that they can carry out due diligence in respect of the sale or purchase, but

only when JE3  has taken reasonable steps to ensure the security and confidentiality of

that information. If JE3 Foundation (or substantially all of its assets) is acquired by a

third party, personal data held about donors or users of its goods, products or services

will be one of the transferred assets.

9. INTERNATIONAL DATA TRANSFERS

We do not currently transfer your personal data outside of the European Economic Area. If this changes in the future, we will update this policy and implement measures to ensure your information is protected.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
    • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

10. HOW WE KEEP YOUR INFORMATION SECURE

JE3 Foundation is committed to ensuring that your information is secure. In order to prevent un-authorised access or disclosure of personal data, we have put in place sufficient technological, physical and managerial procedures to safeguard and secure the information we collect. We regularly test these procedures and have sufficient information recovery and data breach procedures in the event that we encounter any challenges.

11. KEEPING YOUR INFORMATION

JE3 Foundation will retain your personal information for the minimum reasonable time period to allow us to fulfil the purposes for which it is collected as set out in this policy and for any longer period necessary for it to comply with statutory retention obligations and/or for the purposes of defending or making legal claims. Examples of some of our retention periods are set out below:

JE3 Foundation stores:

• Financial transactions: for six years in order to comply with its obligations to maintain adequate accounting records;

• Contracts: for six years so that it has appropriate evidence in place if there is a claim for breach of contract made within the statutory limitation periods;

• Job & volunteer applications and CVs: For up to six months where applicants are not successful, in case other suitable opportunities arise, and for 7 years for successful candidates;

• Account information: until you close or delete your account/profile (at which point we would also delete any information from other companies or market research which we have appended to your account/profile);

• Market research: we have undertaken (and which is not appended to your user account) for 3 years. Note that we will retain aggregated market research information (by which you cannot be identified) on an ongoing basis for internal purposes; and

• save as set out above, information you post online and/or online usage information for 3 years if it is on JE3 Foundation Official Websites.

If any information falls into more than one category then the longer storage period will apply.

12. YOUR DATA PROTECTION RIGHTS

You have several rights under applicable data protection laws (unless an exemption applies), which are summarised below. These rights can be exercised by contacting JE3 Foundation using the details given below in this policy.

You have the following rights:

    • Right to Object: You can ask us not to process your personal data for direct marketing purposes;
    • Right of Access: You can request access to personal information held about you and a copy of it;
    • Right to Rectification: You have the right to obtain, without undue delay, the rectification of inaccurate or incomplete personal data;
    • Right to Erasure: You have the right to obtain, without undue delay, erasure of your personal data in certain circumstances, for example if JE3 Foundation’s processing of your personal data is no longer necessary for the purpose for which we collected it;
    • Right to Restrict Processing: You can restrict the processing of your personal data in certain circumstances rather than having it erased;
    • Right to Object to Processing: You can object to the processing of personal data in certain circumstances;
    • Right to Data Portability: You have the right to receive personal data, which you have provided to JE3 Foundation, in a structured, commonly-used and machine-readable format and transmit that personal data to another data controller, or have JE3 Foundation do so on your behalf where technically feasible;
    • We do not currently use data for automate decision-making. You have the right to be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing;
    • Right to Complain: To exercise these rights, you can contact us using the designated Data Protection Officer email (DPO@je3foundation.org) or by post in the address provided below. If you have unresolved concerns, you have the right to lodge a complaint to the Information Commissioner’s Office about the way in which your personal data is being used (www.ico.org.uk).

You are not required to pay any fee to exercise your rights. If you make a request, we have one month to respond to you.

13. PARENTAL CONSENT / SUPERVISION

One of the JE3 Foundation’s primary aims is to engage with participants and young people in the community. We would therefore ask that parents and guardians supervise their participants when they are online and that participants under  the age of18 do not submit personal information or consent to JE3 Foundation, make purchases of JE3 Foundation’s goods, products or services, or take part in JE3 Foundation events or activitites, without the consent of their parent or guardian. JE3 Foundation reserves the right to take reasonable measures in order to verify the existence and/or validity of parental consent. 

14. HOW TO OPT OUT OF MARKETING

Where you have agreed to receive marketing communications, as part of JE3 related marketing, you can click the ‘unsubscribe’ link in any email marketing communications which we send you.

15. HOW TO CONTACT US

Our Data Protection Officer (DPO) is John Eagleton. If you would like to contact JE3 Foundation about this policy or any of the legal rights outlined in it, you can contact us in writing by email at DPO@je3foundation.org or write to:

FAO: Data Protection Officer

Justin Edinburgh 3 Foundation

12 Franklin Road

Portslade

BN14 1AF

16. CHANGES TO OUR PRIVACY POLICY

Any changes we make to this privacy policy in the future will be posted on this page. Please visit this page frequently to see any updates or changes to this privacy policy.

This privacy policy was last updated in April 2021.