Purpose of this privacy policy

This privacy policy aims to give you information on how Hakuna Matata collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, make a donation or request a grant.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Hakuna Matata is a registered charity with number 1135589 (collectively referred to as “HM”, “we”, “us” or “our” in this privacy policy). HM is the “data controller” and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Data Privacy Manager 
Hakuna Matata
4th Floor | 1 St James's Market,
St. James's,
London 
SW1Y 4AH
info@hakunamatata-charity.com            

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 19 November 2018. Changes to this privacy policy may be made in response to changes to regulation, legislation or HM itself. Therefore, we ask that you come back every now and then to check for any updates. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes grant amounts, donation amounts, bank account and payment card details.
• Transaction Data includes details about payments/donations/grants to and from you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Dataincludes your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website.
• Communications Data includes your preferences in receiving communications (including newsletters and details of fund raising events) from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a grant). In this case, we may have to cancel the relevant agreement but we will notify you if this is the case at the time.

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • request a grant from us;
  • make a donation to us;
  • subscribe to our newsletters;
  • attend our offices (including CCTV footage collected in public areas of our premises (inside and out);
  • attend any fund raising event organised by us;
  • request promotional materials be sent to you;
  • enter a survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 10 for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    1. analytics providers such as Google based outside the EU;
    2. advertising networks; and
    3. search information providers based inside or outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

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

• 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.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which events and other information relating to our charitable activities may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out in the table above:

• External Third Parties as set out in the Glossary.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer personal information we collect about you outside of the European Economic Area (“EEA”) where we use service providers that store information on servers based outside of the EEA. To ensure that your personal information is protected, since the data protection regimes in these locations might be less exacting than within the EEA, we ensure that one of the following safeguards is already in place, or will be put in place prior to transfer:

• the recipient is listed on the EU-US Privacy Shield;
• the recipient has entered into Binding Corporate Rules with us; or
• the recipient has entered into the EU Model Clauses with us. We may also transfer your personal information outside the EEA to partners and associated organisations in connection with the fulfilment of our charitable objectives.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider 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 whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information 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 information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third-party) 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 information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
• Withdraw your consent for us to use your personal information at any time, where we are handling your information on the basis of your consent.

If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our website are being used. Our website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences. We only use this information for statistical analysis purposes and then it is removed from our systems.

A cookie in no way gives us access to your computer or any information about you, other than information about how you use the website and the personal information you choose to share with us (including personal information you automatically share with us by way of your browser settings).

In particular, we use the following cookies:

• Strictly necessary cookies. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas; and
• Performance cookies. These cookies collect information about how visitors use our website, for instance which pages visitors go to most often and if they get error messages from the web pages. These cookies don’t collect information that identifies a visitor; all information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our website works.

You will normally see a message on our website before we store a cookie on your computer which describes the types of cookies we use and what information they might collect.

You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our website.

You can also find more information about cookies generally here: www.allaboutcookies.org

Introduction

• Hakuna Matata has a strong commitment to the principle of equal opportunities and to maintaining a culture that respects and values each other’s differences and that promotes dignity, equality and diversity. We aim to ensure there are no barriers, biases or discrimination that prevent individuals or groups from realising their potential and contributing fully to Hakuna Matata’ performance. We seek to develop a culture that positively values diversity, and that is free from discrimination, victimisation or harassment.
• Hakuna Matata is committed to providing equal opportunities throughout employment, including in the recruitment, training and promotion of employees. Hakuna Matata does not tolerate discrimination, harassment, sexual harassment or bullying in the workplace or in the course of employment. All employees are entitled to be treated with dignity and respect.
• The obligations in this policy apply to employees, interns, agency workers, contractors, suppliers, customers, clients and business contacts who interact with Hakuna Matata employees. For the avoidance of doubt, this policy applies to all employees whether such employees are working at Hakuna Matata’s premises or at home. Appropriate standards of conduct are required while at work and when attending events in the course of employment or engagement by Hakuna Matata, even when outside of normal working hours.
• This policy does not form part of an employee’s contract of employment. Hakuna Matata shall review this policy on a regular basis to ensure that the policy is in line with changes in the law, relevant case law and other relevant developments. Human Resources shall be responsible for ensuring that monitoring, training and reviews of the Equal Opportunities Policy take place.

Equal Opportunities in Employment

Our commitment to equal opportunities applies to all aspects of employment including:

• recruitment and the advertisement of jobs
• terms and conditions of employment
• pregnancy, maternity and parenthood
• pay and benefits
• opportunities for training, career development and progression/promotion
• relationships between members of staff
• work related social events
• contact with customers and clients
• work environment
• working practices
• health & safety

1. Person and job specifications will be limited to those requirements that are necessary for the effective performance of the role. Candidates for employment or promotion will be assessed objectively against the requirements for the role, taking account of any reasonable adjustments that may be required for candidates with a disability. Disability and personal or home commitments will not form the basis of employment decisions except where necessary.
2. Hakuna Matata will comply with our obligations in relation to statutory requests for contract variations and will also make reasonable adjustments to our working practices for individuals with a disability. Hakuna Matata will consider any possible indirectly discriminatory effect of our working practices, and we will refuse requests for variations to working practices only if we have good reasons for doing so, that are unrelated to any protected characteristic.
3. Where possible, Hakuna Matata will monitor the ethnic, gender and age composition of the existing workforce and of applicants for roles (including promotion), and the number of people with disabilities within these groups, and will consider and take any appropriate action to address any problems that may be identified as a result of the monitoring process.

LAWFUL BASIS

Legitimate Interest means the interest of our organisation in conducting and managing our charitable activities to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.