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Privacy policy

Introduction

Welcome to Alpha International’s (AI) privacy notice.

AI respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data (regardless of where you visit this Privacy Policy from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can scroll through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

AI works in partnership with four other independent charities that have a shared heritage and have come out of Holy Trinity Brompton church.  We refer to the charities collectively as the HTB Group (HTBG), but they do not form part of a group within a technical legal definition.  The HTBG work cooperatively and collaboratively with many shared systems, processes and policies.  In light of the close partnership, shared offices and infrastructure the constituent charities of the HTBG have agreed to adopt a common approach to privacy and data protection.  The individual charities have entered into a formal data sharing agreement to regulate the extent to which data may be shared between the charities and the protection and procedures in place to regulate this sharing of data.  Within this privacy notice we will tell you about areas where the HTBG share data and why.

This privacy notice aims to give you information on how AI collects and processes your personal data, including any data you may provide through this website when you interact with us, register for an event, donate to the charity, apply for a role as a volunteer or staff member or sign up to our newsletter.

This website is not intended for children, however, we do collect data relating to children if they attend one of our events or take part in our activities.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

Controller

The HTB Group (HTBG) is comprised of:
Holy Trinity Brompton incorporated and registered in England and Wales with charity number 1133793 whose registered office is at Brompton Road, London, SW7 1JA (HTB).
Alpha International is a charity registered in England and Wales with number 1086179, in Scotland with number SC042906 and a private company limited by guarantee registered in England and Wales with number 4157379 (AI).
St Paul’s Theological Centre is a charity registered in England and Wales with number 1111609 and a private company limited by guarantee registered in England and Wales with number 5543940 (SPTC).
Church Renewal Trust is a charity registered in England and Wales with number 1129661 and a private company limited by guarantee registered in England and Wales with number 6849860 (CRT1).
Church Revitalisation Trust is a charity registered in England and Wales with number 1174882 and a private company limited by guarantee registered in England and Wales with number 10754427 (CRT2).

This privacy notice is issued on behalf of the HTBG so when we mention “HTBG”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant charity in the HTBG responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. AI is the controller and responsible for this website.

We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPL at [email protected], by calling 0207 052 0200, or writing to Data Protection Lead, Alpha International, Cromwell Road, London, SW7 2HR.

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 (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 notice and your duty to inform us of changes

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 notice of every website you visit.

2. The data we collect about you

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:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law because the data does 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 notice.

As a faith-based charity, we collect data about courses, training and events you attend.  This information is likely to come within the definition of Special Categories of Personal Data. Special Categories of Personal Data 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. We will always make it clear to you when we collect this information and why.  For some of our events and services we may also collect information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data to perform the 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. In this case, we may have to cancel your tickets to an event or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you which include:

Direct interactions

We collect your data through the following direction transactions.  This includes personal data you provide when you:

Automated technologies or interactions

As you interact with our website, we may 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. Please see our cookie policy for further details.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies page here.

4. How we use your personal data

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:

Generally we do not rely on consent as a legal basis for processing your personal data other than when we collect Special Categories of Data or in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by clicking on an unsubscribe link in one of our emails to you or by emailing [email protected].


Purposes for which we will use your personal data

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 email *[email protected]*if you need details about the specific legal ground we are relying on to process your personal data.

Fundraising

Where we believe we have a legitimate interest to do so, particularly if you have donated to AI, we may conduct profiling and wealth screening to compile information using publicly available data about you or information that you have already provided to us. Where we have identified that you may have the capacity or affinity to support AI at a higher level, we may use the information we hold about you to identify connections between you and our existing circle of key supporters. We may review other information about you that is available to the public through internet searches, social networks, such as LinkedIn, subscription services, news archives or public databases (e.g. Companies House, the electoral, political and property registers), such as information about corporate directorships, shareholdings, published biographic information, employment and earnings, philanthropic interests and networks, charitable giving history and motivations and relevant media coverage. This information helps us engage with you in a more personalised way.

We may also obtain personal data about individuals who may be interested in giving major gifts to charities or organisations like AI. AI will not retain publicly available data relating to major donors without informing them and providing them with the opportunity to object to our processing of their personal data, which will be done at the earliest practical opportunity. Where we decide not to make contact, we will delete all personal data obtained other than basic contact details which we will apply a suppression flag to ensure we do not make contact in the future.

We may use third party agencies as a cost-effective way to undertake wealth screening on our behalf and share your information with them to the extent required. You will always have the right to object to the processing of your information in this way.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased goods, attended an event or course from us and, in each case, you have not opted out of receiving that marketing.

You can ask us or third parties to stop sending you marketing messages by emailing [email protected] at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, event registration or other financial transactions.

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 email [email protected].

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.

5. Disclosures of your personal data

We will share some of your personal data with the parties set out below for the purposes mentioned in paragraph 4 above.

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.

6. International transfers

Some of our external third parties, National Alpha Offices and Fundraising Partners are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

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

7. Data security

8. Data retention

How long will you use my personal data for?

9. Your legal rights

No fee usually required

What we may need from you

Time limit to respond

10. Glossary

LAWFUL BASIS

THIRD PARTIES

Internal Third Parties:

Fundraising Partners:

National Alpha Offices:

External Third Parties:

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Disclaimer

The content on this website is provided for your personal and private non-commercial use only.  You may not copy, reproduce, distribute, transmit, broadcast, display, sell, license, or otherwise exploit this or any other content for any other purposes without the prior written consent of Alpha International.

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