- the Data Protection Act 2018;
- the General Data Protection Regulation (EU) 2016/679; and
- the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This Policy governs all pages hosted at www.frontlineaids.org and registration for this site. It does not apply to pages hosted by other organisations to which we may link and whose privacy policies may differ. Please read this Policy to understand how your personal information will be treated. This Policy may change from time to time so please check back periodically.
If you’d like to contact us about anything in this Policy, please get in touch with our data protection officer:
Phone: +44 (0)1273 718900
Post: Frontline AIDS, Preece House, 91-101 Davigdor Road, Hove, BN3 1RE, UK
Website: Use the form on our Contact Us page.
How and when do we collect information about you?
We may collect and store information about you when you interact with us, whether through the website or by other means. For example when you:
- Sign up to a newsletter
- Make a donation
- Apply for a job with us
- Participate in an event
- Enter into a contract with us
- Give us feedback
We may also receive information about you when you interact with third parties with whom we work. For example, where you’ve made a donation to us through a third-party website (e.g. JustGiving) and have given them permission to share your information with us.
What information do we collect?
The information we collect from you directly may include:
- Email address
- Telephone number
- Date of birth
- Contact preferences
Also, when you use the Website – for example, to subscribe to an e-newsletter or make a donation – Frontline AIDS automatically collects certain types of information about you including IP addresses, and uses Google Analytics to collect data on pages accessed. (See Cookies section below.)
If you have given your consent to updates and fundraising emails, we may also collect information about your preferences so that we can offer content which we think may be of interest to you. You may withdraw your consent to these emails at any time.
When you are on the Website and are asked for personal information, you are sharing that information only with Frontline AIDS.
A cookie is a text-only string of information that we pass to your computer’s hard disk through your web-browser so that the Website can remember who you are.
Cookies cannot be used by themselves to identify you.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of the Website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Google Analytics (_ga, _gat, _git) Tracking user activity
Aids Alliance (_aidsalliance_session) Identify website visitors
For more information about cookies, including how to turn cookies off, please see www.allaboutcookies.org
How do we use your information?
Frontline AIDS uses the information we collect about you to help us understand more about how our site is used, to make the site more useful, and to be able to send you relevant communications such as our e-newsletters. In particular, we use your personal information for purposes related to providing our services to you, for example verifying and authenticating your identity, processing your payments and completing transactions. We also use such information where necessary to comply with legal and regulatory requirements.
We may use your information:
- To process a donation that you have made
- To process a job application
- For internal record-keeping relating to any donations, feedback or complaints
- To send you communications that you have requested. These could include information about campaigns, appeals and other fundraising activities
- To provide you with information about our work and activities.
Our processing of your personal information will be based on a variety of legal grounds, including (1) where you have provided your consent (e.g. to conduct marketing), (2) where the processing is necessary for the performance of a contract, and (3) where the processing is necessary for the purposes of our legitimate interests, having taken account of your individual interests (e.g. for internal record-keeping and administrative purposes, and to operate and maintain our Website).
We respect your contact wishes, and will only ever contact you by the means you agree to. We will not share your details with anyone. Where you have provided your consent to us processing your personal information, you can withdraw this at any time by writing to us at the contact address above.
Distribution of information
If you have subscribed to Frontline AIDS e-newsletters, we will send you regular communications as specified in the relevant area of the website. You are able to unsubscribe from any of the e-newsletters at any time by altering your preferences by clicking the unsubscribe link at the bottom of each e-mail.
Storing your information
We will only store your information for as long as it is reasonably necessary to do so, for the purposes we have described or as required by law. This may vary depending on the type of information and the purpose for which it has been collected. You can request that we delete your personal information at any time.
You have the following rights when it comes to our handling of your data:
- Right of access – you have the right to request a copy of the personal data we have about you and to request supporting information explaining how the personal data is used.
- Right of rectification – you have the right to request that we rectify inaccurate personal data about you.
- Right of erasure – you have the right to request that we erase all personal data about you.
- Right to restrict processing – in some situations, you have the right to request that we do not use the personal data you have provided (e.g. if you believe it to be inaccurate).
- Right to object, including to direct marketing – you have the right to object to certain processing of your personal data (unless we have overriding compelling grounds to continue processing) and the right to object to direct marketing.
Please get in touch with our data protection officer (firstname.lastname@example.org) if you would like to exercise any of these rights.
Your personal information and privacy are of our utmost concern. Except as explained in this policy, Frontline AIDS will not disclose any of your personally identifiable information, and will not sell or rent lists containing your information to third parties.
Frontline AIDS may disclose information when it has your permission to do so or under special circumstances, such as when it believes in good faith that the law requires it. We may also disclose information if it helps our trusted third party services providers to provide and improve our service to you. These trusted third parties would only be permitted to use your personal information for the purposes we specify. If we need to transfer your data to a company based outside the EU (e.g. if our hosting company is based in the US), we’ll take steps to make sure your personal data is handled in line with EU law.
When you give Frontline AIDS personal information we take steps to ensure that your information is treated securely. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure. As a result, while we strive to protect your personal information, Frontline AIDS cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
Once we receive your information, we use our best efforts to ensure its security on our systems. In an effort to prevent unauthorised access to, or disclosure of, your personal information, we have put in place physical, technical, and administrative safeguards to prevent unauthorised access or use of your personal information.
In order to protect the security of your information, we use encryption technology and firewalls when collecting or transferring sensitive personal information. However, as with any other organisation, we cannot fully eliminate security risks associated with the storage and transmission of personal information over the internet. As such we cannot accept any liability for the loss, theft or misuse of personal information which you have entered on the Website in the event of a security breach. We do not store customer credit card details nor do we share customer details with any third parties.
We take feedback and complaints seriously and will make every effort to resolve any complaint received as soon as possible. If you wish to make a complaint, you can reach our data protection officer at email@example.com or through the main switchboard on +44 (0)1273 718900.
Alternatively, you can write to us at Frontline AIDS, Preece House, 91-101 Davigdor Road, Hove, BN3 1RE, United Kingdom or use the form on our Contact us page. We aim to provide a response within three days and will treat your information confidentially.
If you are not satisfied with the way we have handled your data, you have the right to complain to the UK’s data protection regulator, the Information Commissioner, about our handling of your data.
You can use the relevant section of the Information Commissioner’s Office website to do this: https://ico.org.uk/concerns/.
Frontline AIDS is also registered with the Fundraising Regulator. If your complaint related to fundraising and you feel that we have not resolved it to your satisfaction, you can contact the Regulator here.
We keep this Policy under regular review and may make changes to it from time to time.
This Policy was last updated in January 2019.