Privacy

RIGHT TO VOTE – PRIVACY POLICY

We respect the privacy of every person who visits or registers with https://www.righttovote.co.uk (the “Site”) and uses the Site’s functionality to stay abreast of campaign developments as well as contact politicians and influencers as part of those campaigns (the “Functionality”).

Please note that in this Privacy Policy when we refer to use of the Site we are referring to use of the Site and the Functionality.


1. PURPOSE OF THIS POLICY

This privacy policy explains our approach to any personal information that you might supply to us (or that might be collected from you) including in connection with your use of the Site and sets out your rights in respect of our processing of your personal information. 

This privacy policy will inform you how you can verify which of your personal information is collected by us through the Site and how you can request that we delete, update or transfer it.

This privacy policy is intended to assist you in making informed decisions when using the Site. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.

2. WHO ARE WE AND WHAT DO WE DO?

The Site is operated by RIGHT TO VOTE LIMITED (“we” “us” or “our”) whose principal activities include managing the Right to Vote campaign.

RIGHT TO VOTE LIMITED is the data controller responsible for your personal information as set out in this privacy policy. 

RIGHT TO VOTE LIMITED is an English company with registered company number: 11735221 and whose registered address is 81a Endell Street, London, England, WC2H 9DX. 

3. HOW TO CONTACT US?

If you have any questions about this privacy policy or want to exercise your rights, please contact us by:

  • sending an e-mail to campaign@righttovote.co.uk; or
  • writing to us at The Data Protection Officer, 81a Endell Street, London, England, WC2H 9DX. 

4. WHEN DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?

Personal information is collected from you in the following ways:

  1. Information you voluntarily provide to us.

We collect and maintain personal information that you provide to us (e.g. when registering with us or when you correspond with us) or if you sign up with us at an offline event (e.g. provided us with your details in the process of signing a petition or filling in a request for further information about the Right To Vote campaign, or making a donation).

In particular we collect:

  • name;
  • title;
  • demographic information (such as post code);
  • e-mail address;
  • phone number;
  • financial information (if you make a donation);
  • records of donations;
  • social media log in details that you provide to us; and
  • other information that you provide to us (which may include information provided in any questions, comments or feedback you leave on the site, and may include information used to comply with laws and regulations around political finance).

Other than some information which is required as a minimum to set you up as a user of the Site you have the flexibility to provide us with as little or as much of this requested information as you like. However, the more information you provide, the more you will get out of the Site.

If you contact us, we may collect additional personal information from you such as your opinion on our service.

2. Information we collect through your use of the Site.

Through our use of cookies, log files and other technologies, we collect personal information and other information regarding your mobile device or computer hardware used to access the Site. This includes the following:

  • IP address of device(s) used;
  • browser type;
  • operating system and device type;
  • approximate location (e.g. London);
  • access times and dates; and
  • referring website addresses.

We also collect personal information regarding your use of and activity on the Site. This personal information allows us to deliver more helpful information, services and tools. Please see our Cookie Policy [here] for further information.

3. Information we collect from third parties

We may also combine personal information that we collect as above with personal information that: 

  1. you have provided to third parties and in respect of which you have given the third party permission to share with us (e.g. our third party crowd funding platforms);  and/or
  2. we have obtained from a public record (e.g. the electoral roll).

5. SPECIAL CATEGORIES OF DATA

Data privacy law recognises certain categories of personal information as sensitive and therefore requiring more protection. These categories of data include information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs and health data. Additionally there are further rules concerning the use of criminal data. We will only process this data if there is a valid reason for doing so and where the law allows us to do so.

6. HOW DO WE USE YOUR PERSONAL INFORMATION?

Our primary goal in collecting personal information from you is to

  1. verify your identity,
  2. help us improve the Site, improve our campaigns and develop new campaigns and areas of interest,
  3. carry out requests made by you on the Site,
  4. investigate or settle inquiries or disputes,
  5. comply with any applicable law, court order, other judicial process, or the requirements of a regulator (such as electoral law),
  6. enforce our agreements with you such as our website terms and conditions of use,
  7. to further our organisational purposes,
  8. communicate with you (including to provide updates on our work),
  9. accept donations,
  10. protect the rights, property or safety of us or third parties, including other users of the Site,
  11. prevent fraud,
  12. establish, defend or enforce legal claims,
  13. provide support and security for the Site, and
  14. use as such information as otherwise required or permitted by law.

The law requires us to have one or more legal basis for processing your personal information. In particular, we consider the below to be relevant where we use your personal information for the following purposes:

  • Provision of the Site.

We use this information to communicate with you, to carry out digital campaigning, to fulfil actions you request on the Site, such as requests for support, and to track the transaction/requests that are performed. This activity may include conducting digital campaigning by emailing politicians and other decision-makers on important issues when you request us to do so using the Functionality (and we will share your information with these third parties for this purpose).

What is our legal basis?

We will obtain your explicit consent to use your personal information for the provision of Site and the Functionality.

  • Information Requests and Feedback.

Our Site contains various user interfaces to allow visitors to request more information about our services, to use the functionalities of the site, or to provide us with feedback about them.

Contact information may be requested in each case, along with information about your computing environment and/or industry, and details of your request or reported feedback. This information is used in order to allow us to respond to your requests, to assure that our software and services work correctly.

What is our legal basis?

We will obtain your explicit consent to use your personal information for the provision of Site and the Functionality. It is also in our legitimate business interests to respond to any requests you make to us or use the information you provide to us in your feedback in order to improve our products and services.

  • Surveys/Campaign Questionnaires.

It is likely that surveys and/or campaign questionnaires will appear on the Site or be sent to you via e-mail, and in such case, where you volunteer to participate, we collect personal information from you as part of the survey and or questionnaire. This information will be used to administer the survey, to analyse its results and for other specific purposes, which are disclosed at the time of collection. Survey responses will be aggregated and depersonalised before survey results are shared with any third parties.

What is our legal basis?

By voluntarily participating in our surveys and or questionnaires we rely on your consent to use the personal information we collect as part of such survey. It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service, campaign information and feedback we can to you.

  • Profiling. For more information see below.

We use your information for user profiling to ensure that our campaign and any messages we send you are as effective as possible.

What is our legal basis?

We will obtain your explicit consent to use your personal information for the provision of Site and the Functionality. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service, campaign information and feedback we can to you. 

  • Site administration. For more information see below.

We use your personal information to:

  1. develop and improve the Site and Functionality;
  2. send you administrative e-mails about the Site; and
  3. contact you to answer any queries you may have.

What is our legal basis?

We will obtain your explicit consent to use your personal information for the provision of Site and Functionality. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service, campaign information and feedback we can to you. 

  • User Data Analysis. For more information see below.

Our web pages and e-mails contain "web beacons" or “pixel tags.” Web beacons and pixel tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site (and use this information to improve the Site). This allows us to learn what pages are most attractive to our visitors, which parts of our Site is the most interesting and what kind of information our registered users like to see. Some of the web beacons that are placed on our Sites are used only by us, and other web beacons are used by our service providers on our behalf to analyse how our Site is being used. Once you click on an e-mail that contains a web beacon, your contact information is subsequently be cross-referenced to the source e-mail and the relevant web beacon or pixel tag information.

In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymous form, we will obtain your explicit consent to use your personal information for the provision of Site and the Functionality. 

  • Internal record keeping and legal compliance. For more information see below.

We use your personal information for internal record keeping purposes and to check you comply with the Site and Website Terms of Use.

What is our legal basis?

We will obtain your consent to use your personal information for the provision of Site and the Functionality. It is also in our legitimate interest to ensure that we keep our records up-to-date in order to monitor who uses the Site and Functionality, to comply with our legal obligations and to monitor your compliance with the relevant Terms of Use. 

  • Campaign updates, promotional and marketing messages and communication from us.

If you have consented to us doing so we will add you to our mailing list for purposes of campaign updates, promotional and marketing messages and other communications. This mailing list is used to provide you with further information about Right to Vote if you want it. We will communicate with you about the campaign and associated causes of Right to Vote.

What is our legal basis?

We will obtain your consent where the law requires before sending you such campaign updates, promotional and marketing messages and other communications, particularly where doing so by electronic means (such as email). 

Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy policy or otherwise from time to time including the legal basis of such use.

7. DO WE SHARE YOUR PERSONAL INFORMATION?

We may disclose your personal information to selected third party data processors for the purposes outlined in this privacy policy. The third party in question will be required to use any personal information they receive in accordance with our instructions.  

We reserve the right to disclose your personal information to third parties:

  1. in the event that we buy or sell any business or assets, in which case we will disclose your personal information to the prospective buyer or seller or such business or assets;
  2. if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
  3. with our professional advisors e.g. lawyers,  where necessary to protect our interests; 
  4. if we are under any legal or regulatory obligation to do so; and
  5. in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.

8. USE OF COOKIES

Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy [here] to find out more about the cookies we use and how to manage and delete cookies.

9. THIRD PARTY LINKS AND SERVICES

It is likely that the Site will contain links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this privacy policy no longer applies. 

Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This privacy policy applies solely to personal information collected by us through our Site and does not apply to these third party websites and third party service providers.

10. TRANSFERS OUTSIDE THE EEA

Generally we do not transfer your personal information outside of the UK or the EEA.

As we sometimes use third parties to process personal information on our behalf, it is possible that personal information we collect from you will be transferred to a location outside the UK or EEA.

Certain countries outside of the UK and EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred outside the UK or EEA in a country which does not offer an equivalent standard of protection, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. For instance, we may use cloud providers to store personal information who have servers in the US and are signed up to the Privacy Shield. If you have any questions about the transfer of your personal information, please contact us using the details at Section 1.

11. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We will not keep your personal information for longer than is necessary for our purposes. This will be a maximum of 6 years following collection to comply with the typical limitation period in English law.

In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations. In some cases we may keep your personal information for longer so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

If your information is only useful for a short period e.g. for specific campaigns we will delete it once it is no longer required for relevant purposes.

If you would like further information about this, please contact us using the details at Section 1 above.

12. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. 

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Site.

13. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS

You have the following rights in relation to the personal information we hold about you (please note that these are legal rights subject to exemptions and in some cases we may need to first confirm your identity and entitlement):

  • Your right of access. You can ask us to confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Your right to rectification. If you believe the personal information we hold about you is inaccurate or incomplete, you’re entitled to ask for it to be rectified. If we’ve shared this information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to data portability. You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
  • Your right to object. You can ask us to stop processing your personal information, and we will do so, if we’re: 
    • relying on legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
    • processing your personal information for direct marketing; or
    • processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
  • Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
  • Your right to withdraw consent. If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

To seek to exercise any of the above rights, please contact us using the details in Section 1 above.

  • Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

14. CHANGES TO THIS PRIVACY POLICY

We may make changes to this privacy policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this privacy policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy policy periodically to be informed of how we use your personal information.

Dated: 03 May 2019

Media Contact

Mark Holdsworth
m.holdsworth@righttovote.co.uk
+44 (0)203 404 0553