Last update: 1 January 2024
Why and who?
Lonely Orphans cares about privacy and protecting all Personal Data handled by us.
This policy describes how and why we use your Personal Data, the lawful basis on which we use your Personal Data and what measures we take to protect it. It also provides information on how to exercise your rights in connection with our Processing of Personal Data.
This Policy provides information on how we handle Personal Data when you communicate with us, use the Services, buy our products or visit our website, www.lonelyorphans.org.
Data subjects and storage time:
The intended recipients of this Policy are the following groups, whose data we store in accordance with the criteria set out below.
- Users of the Services: Personal data of the users will be stored during the period that they use the Service and to comply with legal obligations, such as handling alleged errors in the Service.
- Potential customers: Personal data of potential customers will be stored during the period required to determine whether or not they wish to enter into an agreement.
- Customers: Personal data of customers will be stored during the period it takes to deliver products and during the period necessary to comply with legal obligations, such as handling a reclamation.
- Employees of potential customers: Personal data of employees at potential customers will be stored for the period required to determine whether the potential customer wants to enter into an agreement.
- Employees of existing customers: Personal data of employees at an existing customer will be stored during the time required to provide the service and to fulfil legal obligations
Applicable Law refers to the legislation applicable to the Processing of Personal Data,including the UK GDPR, supplementary national legislation, as well as practices, guidelinesand recommendations issued by the Commissioner or other relevant regulatory authority.
Commissioner means the Information Commissioner’s Office (the UK regulator for dataprotection issues).
Controller is the company/organisation that decides for what purposes and in what waypersonal data is to be processed and is responsible for the Processing of Personal Data inaccordance with Applicable Law.
Data Subject is the living, natural person whose Personal Data is being processed.
Personal Data is all information relating, directly or indirectly, to an identifiable naturalperson.
Processing means any operation or set of operations which is performed on Personal data,such as storage, modification, reading, handover and similar.
Processor is the company/organisation that processes Personal Data on behalf of theController and can therefore only process the Personal Data according to the instructions ofthe Controller and the Applicable Law.
Services means charitable activities.
Special Category of Personal Data or Sensitive Personal Data means any informationthat reveals ethnic origin, political views, religious or philosophical beliefs, trade unionmembership, genetic data, biometric data to uniquely identify a natural person, healthinformation or information about a physical person’s sexual life or sexual orientation.
UK GDPR means the retained EU law version of the General Data Protection Regulation((EU) 2016/679).
The definitions above shall apply in the Policy regardless of whether they are capitalised ornot.
Lonely Orphans’s role as a Controller
The information in this Policy covers Personal Data Processing for which Lonely Orphans isthe Controller. As a Controller we are responsible for the Processing for which we decide thepurpose of (the why) and the means of the Processing (what methods, what Personal Dataand how long the Personal Data is stored). The Policy does not describe how we ProcessPersonal Data in the role of a Processor (i.e. when we process Personal Data on behalf ofour customers).3 (7)
Lonely Orphans’s Processing of Personal Data
We have a responsibility to describe and demonstrate how we fulfil the requirements that areimposed on us when we Process your Personal Data. This section aims to give you anunderstanding of what type of Personal Data we Process and the lawful basis on which weProcess that Personal Data.
In order for us to be able to process your Personal Data, it is required that we have so-calledlegal basis for each process. In our business, we process your personal data mainly on thefollowing grounds:
Consent – Lonely Orphans may process your personal data after you have given yourconsent to the Processing. Information regarding the processing is always provided inconnection to the request of consent.
Performance of a contract – The Processing is necessary for the performance of a contractentered between us and the Data Subject, or to prepare for entering into an agreement withthe Data Subject.
Legitimate interest – Lonely Orphans may process Personal Data if we have assessed thata legitimate interest overrides the interest of fundamental rights and freedoms of the DataSubject, and if the processing is necessary for the purpose in question.
Legal obligation – We are required by laws and regulations to process Personal Data as aresult of our business.
The main purpose of the Processing undertaken by us is to provide, carry out and improveour services to you. There are several different reasons why we may need to collect,manage and save your data.
We mainly Process the following types of Personal Data:
- Contact details to be able to confirm your identity, to verify your personal and contactdetails and to be able to communicate with you
- Personal financial details to be able to carry out KYC and risk analysis when applicable
- Information on your usage of the service or product to improve our services provided to you
- IP-address to perform customer analysis and for content on our site to be presentedeffectively to you and the device you use
- Usage patterns to be able to provide you with specific offers
- Payment information to be able to offer (for example direct debit and other paymentoptions)
Condition for Processing Special Category of Personal Data: We are a foundation,association or any other not-for-profit body with a political, philosophical, religious or tradeunion aim and we only process Special Category data that relates to the members or toformer members of the body or to persons who have regular contact with it us (art 9.2.d UKGDPR).
How do we collect your Personal Data?
We collect your Personal Data in a number of different ways. We mainly collect your Personal Data:
- By you providing your Personal Data to us
- By your employer providing your Personal Data to us
- By social media such as Facebook or Instagram
- Through third-party analysis technology such as cookies
- When conducting KYC (Know your customer) checks
- Through our security systems
- Through our logs
- Through information created from data analysis
- Through generated information that has been obtained internally
You are the one in control of your Personal Data and we always strive to ensure that you canexercise your rights as efficiently and smoothly as possible.
Access – You always have the right to receive information about the Processing of data thatconcerns you. We only provide information if we have been able to verify that it is you thatare requesting the information.
Rectification – If you think that any of your Personal Data that we process is incorrect, let usknow and we will fix it!
Erasure – Do you want us to completely forget about you? You have the right to be forgottenand request deletion of your Personal Data when the Processing is no longer necessary forthe purpose for which it was collected. If we are required to retain your information underapplicable law or a contract that we have entered with you, we will ensure that it isprocessed only for the specific purpose set forth in such applicable law or contract. We willthereafter erase the information as soon as possible.5 (7)
Objections – Do you disagree with our assessment that a legitimate interest for Processingyour Personal Data overrides your interest in protecting your privacy? Don’t worry – in suchcase, we will review our legitimate interest assessment. Of course, we add your objection tothe balance and make a new assessment to see if we can still justify our Processing of yourPersonal Data. If you object to direct marketing, we will immediately delete your personalinformation without making an assessment.
Restriction – You can also ask us to restrict our Processing of your Personal Data:
- Whilst we are Processing a request from you for any of your other rights;
- If, instead of requesting erasure, you want us to limit the Processing of Personal Datafor a specific purpose. For example, if you do not want us to send advertising to you inthe future, we still need to save your name in order to know that we should not contactyou; or
- In cases where we no longer need the information in relation to the purpose for which itwas collected, provided that you do not have an interest in retaining it to make a legalclaim.
Data portability – We may provide you with the data that you have submitted to us or thatwe have received from you in connection with a contract that we have entered with you. Youwill receive your information in a commonly used and machine-readable format that you cantransfer to another personal data manager.
Withdraw consent – If you have given consent to one or several specific Processing(s) ofyour Personal Data, you have the right to withdraw your consent at any time and thus ask usto terminate the Processing immediately. Please note that you can only withdraw yourconsent for future Processing of Personal Data and not for Processing that has alreadytaken place.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
Transfer of personal data
In order to run our business, we may need help from others who will process Personal Dataon our behalf, so-called Processors.
We process all our personal data within the UK or the EU/EEA.
We have entered into Data Processing Agreements (DPA) with all our Processors. The DPAsets out, among other things, how the Processor may process the Personal Data and whatsecurity measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities inorder to fulfill obligations under applicable law or legally binding judgements.
Lonely Orphans does not sell your Personal Data to third parties and of course we do notshare your Personal Data with just anyone. However, in some cases we may need to shareyour Personal Data with selected third parties. If so, we make sure that the transfer happensin a secure way that protects your privacy. To follow are categories of recipients with whomwe may share your data.
- Advertising agencies and suppliers of print and advertising.
- Suppliers of various HR systems or HR services.
- IT suppliers for cloud storage, business systems and case/project management. Inorder to be able to carry out our assignments and services, we store your PersonalData in our business systems (a system that administers our customers and contacts).
- Statistics to contribute to industry statistics and to improve the customer experience.
Lonely Orphans has taken technical and organisational measures to ensure that yourPersonal Data is processed securely and protected from loss, abuse and unauthorisedaccess. Organisational measures are measures that are implemented in work methods androutines within our organisation. Technical measures are measures implemented throughtechnical solutions. In case your Personal Data is shared with Processors, your PersonalData will be equally protected.
Organisational security measures:
- Internal governance documents such as policies or instructions
- Login and password management
- Information security policy
- Physical security (premises etc.)
- Data protection impact assessments
Technical security measures:
- Access control levels
- Access logs
- Secure networks
- Data back-ups
- Regular security inspections
- Two-step verification
If we don’t keep our promise
If you think that we are not Processing your Personal Data correctly, even after you havenotified us of this, you are always entitled to submit your complaint to the Commissioner. Youcan contact the Commissioner on 03031231113 or via email https://ico.org.uk/global/contact-us/email/.
More information about our obligations and your rights can be found athttps://www.gov.uk/government/publications/data-protection-rights-for-data-subjects/data-protection-rights-for-data-subjects.
Changes to this policy
We reserve the rights to make changes to this Policy. In the event that the change affectsour obligations or your rights, we will inform you about the changes in advance so that youare given the opportunity to take a position on the updated policy.
We have appointed a Data Protection Officer who can answer questions about your rightsand other questions about how we process your personal information.
Contact information for Lonely Orphans data protection representative:
Name: Kayrul Islam