Leave Means Leave Website Privacy Notice
Leave Means Leave is committed to protecting the privacy of those with whom it interacts, and Leave Means Leave recognises the need to respect and protect information that is collected or disclosed to us (called “Personal Information”, explained below).
This Privacy Notice is intended to tell you how we use your Personal Information and is in a layered format to give you enough detail to give you the information you need at a glance, with the option of following a link if you want to find out more. If you still can’t find the information you need, you can contact Leave Means Leave by reference to the details set out in section 1 below.
Leave Means Leave is a not-for-profit company limited by guarantee and is a pro-Brexit political pressure group organization (“LML“, “we” and “us” respectively).
We are the controller of your Personal Information (as defined below). We are a registered fee payer with the Information Commissioner’s Office (registration number ZA454935). We have appointed a Data Protection Officer 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 our Data Protection Officer using the following details:
Leave Means Leave
83 Victoria Street
0203 585 4073
Website: www.leavemeansleave.eu/ (“our website“)
What is Personal Information, and which Personal Information do we collect about you?
For the purposes of this Privacy Notice “Personal Information” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.
We may collect use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
- Identity and Contact Data includes first name, last name and title, address and email address.
- Financial Data includes your credit or debit card details, billing address and donations made to LML.
- Technical Data includes internet protocol (IP) addresses, usage session dates and duration, page views, how you use our website, the type of browser used while visiting our website and the numbers of users who visit our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
- Special categories of data includes details of your political opinions.
How is your Personal Information collected?
We use different methods to collect data from and about you including:
- Personal Information that you provide directly. You may give us your Identity and Contact Data, Marketing and Communications Data, Financial Data and Special Categories of Data by filling in forms on our website, requesting information about our campaign and our events, subscribing to receive marketing communications, providing your information when you attend one of our events or by corresponding with us by email, phone or otherwise.
- 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 Information by using cookies and other similar technologies. Please see section 10 below.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from third party analytics providers, such as Google Analytics.
- Identity and Contact Data from publicly available including, Facebook and twitter.
How do we use your information?
We will only use your Personal Information when the law allows us to do so. Most commonly, we will use your Personal Information 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. The legitimate interests we rely on are set out next to each purpose below.
- Where we have obtained your consent.
- Where we need to comply with a legal obligation.
We process your Special categories of data on the basis that the processing is carried out in the course of our legitimate activities as a not-for-profit body with a political aim and that we only process Special categories of data relating to our members, former members or to individuals with whom we have regular contact in respect of LML’s purposes. We do not disclose your Special categories of data to third parties without your prior consent.
Purposes for which we will use your Personal Information
We may use the Personal Information that we collect for the following purposes. For each purpose, we describe the legal bases we rely on to justify such use of your Personal Information.
|Purpose/Activity||Type of data||Legal basis|
|To provide you with information about LML that you specifically request from us||(a) Identity and Contact||(a) Necessary for our legitimate interests in promoting LML and providing you with the information you have specifically requested|
|Provide you with information related to our campaign, events and donation opportunities which we feel may be of interest to you||(a) Identity and Contact
(c) Marketing and Communications
|To enable you to make a donation to LML||(a) Identity and Contact
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests in enabling our supports to make donations
|To enable you to volunteer at one of our events||(a) Identity and Contact||(a) Performance of our volunteer contract with you
(b) Necessary for our legitimate interests in ensuring the successful and effective operation of LML events
|Analysis purposes – for assessment and analysis of our supporters and to create promotional plans||(a) Identity and Contact||Necessary for our legitimate interests to study how our clients use our services, to develop our services and to inform our marketing strategy|
|For security purposes and to administer our website – to maintain and enhance the website and to ensure that content from it is presented in the most effective manner for you and your computer, and to enhance the user experience;||(a) Identity and Contact
|(a) Necessary for our legitimate interests in running LML, to ensure the security of our systems, to assist us in the provision of administration and IT services, network security and to prevent fraud
(b) Necessary to comply with a legal obligation
|Internal record purposes – for monitoring and record keeping including maintaining our accounts, complying with good practice and for other administrative, operational and security reasons||(a) Identity and Contact
(c) Marketing and Communications
|(a) Necessary for our legitimate interests in running LML efficiently and successfully and in order to keep our records updated
(b) Necessary to comply with a legal obligation
|To prevent and detect crime, fraud or corruption and to meet our legal, regulatory and ethical responsibilities||(a) Identity and Contact
|Necessary to comply with our legal obligations|
We may use your Personal Information to provide you with email notifications and other communications by email, on the basis that we have obtained your specific opt-in consent to do so. For further information on this, see the ‘Your Choices’ section of this Privacy Notice.
Combining Personal Information
We may combine the Personal Information that we collect from you to the extent permitted by applicable law. For example, we may combine various different databases that contain your Personal Information to allow us to provide better support services and more personalised content (such as marketing). Client to confirm if applicable]
Change of purpose
Where we need to use your Personal Information for another reason other than for the purpose for which we collected it, we will only use your Personal Information where that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
To whom do we disclose your information?
We will only disclose your information to the following entities:
Regional and National Organisers
We will disclose your Personal Information to our regional and national event organisers to enable you to attend our rallies and events and to provide the information or services you request. All regional and national organisers are required to follow the privacy practices set forth in this Privacy Notice, or such other privacy notice that they may notify to you.
We use third party service providers to help us to administer certain activities and services on our behalf, such as IT and cloud services, marketing services and payment facilitators. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. We currently use the following third-party service providers:
- IT Service Provider – we use Office365 to provide us with IT and cloud services.
- Marketing services – we use MailChimp to send out our marketing communications, and Growl Political (Growl Worldwide Ltd.) to provide us with marketing and media analysis and advice.
- Payment facilitator – we use PayPal to provide us with payment facilitation services.
Third parties when required by law
We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies (in which case such agencies or regulators will be acting as controllers as well); to protect the users of the website (e.g. to prevent spam or attempts to defraud them); to operate and maintain the security of the website (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights or property.
Other Parties At Your Direction
We may share Personal Information about you with third parties when you request such sharing.
What do we do to keep your information secure?
We have put in place appropriate physical and technical measures to safeguard your Personal Information. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. When we use service providers to assist us in processing your Personal Information, we have written contracts in place with such service provider which means that they may not do anything with your Personal Information unless we have instructed them to do it.
However, please note that although we take appropriate steps to protect your Personal Information, no website or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.
International Transfer of Data
The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area (“EEA“), including but not limited to the United States of America or in any other country where our service providers maintain facilities.
By using the website and/or providing us with your Personal Information, you acknowledge that we will collect, transfer, store and process your information outside the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located.
Where we transfer your Personal Information outside the EEA to third parties, we will ensure that appropriate transfer agreements and mechanisms are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information. We rely on [Client to insert safeguards]. We will only transfer your Personal Information outside the EEA in accordance with applicable laws or where you have given us your consent to do so.
Data Retention – How long we will store/keep your Personal Information
We will only retain your Personal Information for as long as the Brexit campaign lasts. As soon as the campaign has finished, we will delete your Personal Information in accordance with applicable law.
In some circumstances you can ask us to delete your Personal Information (see section 8 below).
Accessing your Personal Information and other rights you have
Leave Means Leave will collect, store and process your Personal Information in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have the following rights in relation to your Personal Information:
- Subject Access – you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.
- Right to Withdraw Consent – where you have consented to our processing of your Personal Information, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 1.
- Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.
- Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.
- Erasure (‘right to be forgotten’) – you have the right to have your Personal Information ‘erased’ in certain specified situations.
- Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information.
- Object to processing – you have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.
- Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing.
Enforcing your rights
If you wish to enforce any of your rights under applicable data protection laws, then please see section 1 above. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may, if permitted to do so by applicable data protection laws, charge a reasonable fee for dealing with your request which we will notify to you.
If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner’s Office (www.ico.gov.uk) which is the data protection regulator in the UK which is where Leave Means Leave is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.
Our website may contain links to other third party websites that are not operated by Leave Means Leave. These linked sites and applications are not under Leave Means Leave’s control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites, any Personal Information collected by the third party’s website will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.
What are cookies?
Cookies collect and store information about a user’s preferences, product usage and content viewed which allows for us to provide users with an enhanced and customised experience when engaging with the website.
We use traffic log cookies to identify which of our website pages are being used. This helps us to analyse data about web page traffic and improve our website in order to tailor it to users’ needs. We only use this information for statistical analysis purposes and then the data is removed from our system.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies but you can usually modify your browser setting to decline cookies if you prefer. However this may prevent you from taking full advantage of our website.
Your Choices (e.g. marketing-related emails or otherwise)
When you request information on or from the website, or otherwise communicate with us, we may use your Personal Information (such as your contact details (e.g. name, address, email address, telephone number)) to send you marketing-related correspondence by email related to our products. When we process your Personal Information for marketing purposes, we do so on the basis that we have obtained your consent to use your Personal Information for these purposes.
We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.
You may opt-out of receiving marketing-related correspondence from Leave Means Leave at any time. If you wish to do so, please click “Unsubscribe” from any marketing or promotional email you receive from us.
Changes to this Privacy Notice
It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.
We will provide notice to you if these changes are material and, where required by applicable law, we will seek your consent. We will provide this notice by email or by posting notice of the changes on our website.
Date last updated : [September] 2018