01. WHO WE ARE
This is the Privacy Notice for TRIBE Freedom Foundation, incorporated in England, with charity number 1172251, of LM 13.3.1, The Leathermarket, 11-13 Weston Street, London, SE1 3ER.
We are a UK charity on a mission to fight modern slavery. Our objectives include:
1. Increasing Public Awareness:
Communities are engaged to help build awareness of modern slavery across their wider networks and increase the level of public understanding.
2. Long-Term Survivor Support:
More survivors are holistically supported to help regain independence and overcome their previous exploitation, for as long as they need.
3. Preventing Modern Slavery:
Stakeholders, communities and individuals are equipped with the tools to better understand, identify and tackle the causes of modern slavery.
The TRIBE Survivor Financial Empowerment Hub was created to equip financial institutions and survivor support organisations with the tools needed to empower survivors of modern slavery. Together, we are helping to promote long-term financial well-being, freedom and stability.
02. ABOUT THIS NOTICE
The content found on this website or by following any link herein is being provided to you by TRIBE Freedom Foundation for informational purposes only. TRIBE Freedom Foundation and its partners, including Nasdaq Inc and its subsidiaries (“Partners”), make no representation or warranty with respect to this communication or such content and expressly disclaim any implied warranty under law.
At the time of publication, the information herein was believed to be accurate, however, such information is subject to change without notice. Nothing herein shall constitute a recommendation, solicitation, invitation, inducement, promotion, or offer for the purchase or sale of any investment product, nor shall this material be construed in any way as investment, legal, or tax advice, or as a recommendation, reference, or endorsement by TRIBE Freedom Foundation or any of its Partners.
Our privacy and cookies policy describes what personal data we collect in connection with the provision of our charitable programmes, why we need that data, and how we use it. We aim to ensure that any personal information we obtain and use about you will always be held, used and transmitted in compliance with all applicable data protection legislation.
We will not disclose your personal information to any third parties for marketing purposes. Our website provides a small number of links to other websites, which are beyond our control. We encourage you to read the privacy statements on the other websites you visit.
We do sometimes update this policy from time to time by changing it on the Site. You may therefore want to return here regularly to view our most up-to-date policy. We will publish our privacy notice on our website (available at https://tribesurvivorempowerment.org) and we’ll do our best to update you directly if we think the changes might materially affect you.
Ultimately, we are committed to protecting your privacy online. We know that providing personal information is an act of trust and we take that trust seriously. We appreciate that you do not want the personal information you provide to us distributed indiscriminately or used in ways you would not expect. For your ease of reading, we have set out the key sections of our policy below.
03. WHAT TYPE OF PERSONAL DATA DO WE COLLECT?
3.1 The type of personal data we collect depends on the purposes for which we will need to use it.
3.2 The personal data we collect when you make an enquiry or contact us includes your name, email address, and phone number. We collect this data to communicate effectively with you.
3.3 If you are a supporter, for example, donating, volunteering, registering to fundraise, or signing up for an event, in addition to asking for your name and contact details (your address, email address and your phone number) we may also ask for your professional qualifications, position held or your volunteer role and why you chose to support our work.
3.4 All donations and payments, including those by debit or credit card, are processed securely.
3.5 If you are a grant or job applicant, the personal data you are asked to provide is as set out in the application form and is limited to the information necessary for us to consider the application.
3.6 Visitors to Our Websites:
Our websites include https://tribesurvivorempowerment.org and https://tribefreedomfoundation.com/.
3.7 Marketing and Events:
From time to time, we also may identify people who are likely to find our events or programmes useful for their jobs by looking for business contact details and information about an individual’s job role on publicly available resources and business websites.
Our team will use those business contact details to send event invites and emails about relevant industry news. We use your personal data in this way to maximise the impact of our charitable programmes.
We always include an unsubscribe link at the bottom of any such email which we send, so that you can let us know if you do not wish to receive any further marketing emails.
4. HOW DO WE COLLECT YOUR PERSONAL DATA?
4.1 We may collect your personal data when you contact us or have any involvement with us, for example when you:
4.1.1 work for us, as either a paid employee or volunteer;
4.1.2 visit our website (see our Cookies Policy in Section 13);
4.1.3 donate to us or fundraise for us;
4.1.4 enquire about our activities or services;
4.1.5 sign up to receive news about our activities;
4.1.6 create or update a profile [online];
4.1.7 post content onto our website/social media sites;
4.1.8 volunteer for us;
4.1.9 attend a meeting with us and provide us with information;
4.1.10 take part in our events;
4.1.11 contact us in any way including online, by email, phone, SMS, social media or post.
4.2 We may also collect your personal data when you give it to us indirectly:
4.2.2 it may be provided to us by other organisations if you have given them your permission to share your personal data with us. This might for example be a charity working with us or might be when you buy a product or service from a third party organisation.
4.2.3 it is available on social media: Depending on your settings or the privacy policies applying for social media and messaging services you use, like Facebook, Instagram or Twitter, you might permit us to access information from those accounts or services.
5. HOW DO WE USE YOUR PERSONAL DATA?
5.1 We use your personal data for a number of purposes consistent with the legal basis we rely on when processing your data. These purposes include:
5.1.1 providing you with the information or services you have asked for;
5.1.2 processing donations you make, including processing for Gift Aid purposes;
5.1.3 organising volunteering activity you have told us you want to be involved in and in relation to the fundraising for us you are involved in;
5.1.4 sending you communications with your consent that may be of interest including marketing information about our services and activities, campaigns and appeals asking for donations and other fundraising activities and promotions for which we seek support;
5.1.5 when necessary for carrying out our obligations under any contract between us;
5.1.6 seeking your views on the services or activities we carry on so that we can make improvements;
5.1.7 maintaining our organisational records and ensuring we know how you prefer to be contacted;
5.1.8 analysing the operation of our website to improve its usefulness (please see our Cookies Policy for more details);
5.1.9 processing grant or job applications;
5.1.10 providing support to beneficiaries of the Charity’s services.
5.2 We do not use your personal data for any automated decision-making, including profiling.
6. OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
6.1 The use of your personal data for the purposes set out above is lawful because one or more of the following applies:
6.1.1 where you have provided your personal data to us for the purposes of requesting information or requesting that we carry out a service for you, we will rely on the lawful basis of legitimate interests (the Charity’s or of a third party) or, where appropriate, we will collect your consent. Where we collected your consent, you may withdraw it at any time by emailing us at firstname.lastname@example.org. This will not affect the lawfulness of processing of your information prior to your withdrawal of consent;
6.1.2 it is necessary for us to process your personal data to carry out our obligations under a contract entered into with you or to take steps you ask us to take prior to entering into a contract;
6.1.3 it is necessary to comply with our legal obligations;
6.1.4 where we are relying on the fact that a particular processing purpose is necessary for our legitimate interests, or the legitimate interests of a third party, you can obtain information about the balancing test we have undertaken by contacting our Privacy Officer via email@example.com.
7. HOW DO WE KEEP YOUR PERSONAL DATA SAFE?
7.1 We understand the importance of the security of your personal data and take appropriate steps to safeguard it.
7.2 We implement adequate technical and organisational measures to ensure a level of security appropriate to the risks of our processing of your personal data. We require all those with access to personal data within the Charity to comply with organisational and technical measures that we have put in place to protect any personal data that we need to use. Where your personal data is stored electronically, it is held on a password-protected database to which employee access is restricted to key individuals on a ‘needs to know basis.’ Paper files are stored in locked cabinets to which employee access is restricted to key individuals on a ‘needs to know basis.’
7.3 We always ensure that authorised persons who have access to your information, which means only our staff, volunteers and contractors, are appropriately trained to ensure the security and integrity of your personal data and are subject to confidentiality undertaking.
7.4 While no data transmission over the internet can be guaranteed to be 100% secure, we strive to safeguard your personal data and mitigate any inherent risk as far as possible.
8. WHO HAS ACCESS TO YOUR PERSONAL DATA?
8.1 The following categories of recipients may have access to your personal data:
8.1.1 Third parties who provide services for us, for example, the mailing house that prints our supporter appeals, our payroll provider and our HR and pensions advisers. We select our third-party service providers with care. We provide these third parties with only that data that is strictly necessary to provide the service and we have appropriate agreements in place that require them to comply with data protection laws and protect your personal data with the same care as we do.
8.1.2 Third parties if we run an event in conjunction with them. We will let you know how your data is used when you register for any event.
8.1.3 Analytics and search engine providers that help us to improve our website and its use.
8.1.4 Third parties in connection with or as a result of restructuring or reorganisation of our operations, for example, if we merge with another charity. In such an event, we will ensure your personal data and privacy rights will be protected by the third party.
8.2 Owing to matters such as financial or technical considerations, we may need to transfer your personal data to countries outside the European Economic Area (EEA), which are not subject to the same data protection regulations as apply in the UK. We may do this where data is stored on servers outside the EEA or where we use suppliers based outside the EEA. We meet our obligations under UK GDPR by ensuring that personal data has equivalent protection as if it were being held within the EEA. We do this by ensuring that there are appropriate safeguards in place with any third parties processing your data outside the EEA. This will usually be because the country either benefits from an adequacy determination for the UK GDPR purposes and/or we have entered into a Data Processing Agreement with the third party which contains EU standard contractual clauses recognised as a valid data transfer mechanism in the UK.
8.3 We may also disclose your personal data or may use external data if we are required to do so under any legal obligation where we otherwise have a lawful basis to do so (for example for fraud prevention and credit risk reduction).
9. KEEPING YOUR INFORMATION UP TO DATE
We take care to ensure that the personal data we hold is up to date and we would appreciate it if could you let us know when your contact details change.
You can do so by contacting us:
Postal address: LM 13.3.1, The Leathermarket, 11-13 Weston Street, London, SE1 3ER
10. CHILDREN’S INFORMATION
Our services are aimed at individuals of working age and we do not proactively seek out children’s data but we appreciate that our supporters are of all ages. Whenever we collect personal data of children (under the age of 16 years), we will ask for consent from a parent or guardian.
11. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
11.1 We will hold your personal data for as long as it is necessary for the relevant processing purpose. By way of example, we hold records of donations you make for at least six years so we can fulfil our statutory obligations for tax purposes. Please contact the Privacy Officer at firstname.lastname@example.org for further details.
11.2 Where we rely on your consent to contact you for direct marketing purposes, we will treat your consent as lasting only for as long as it is reasonable to do so. We will periodically ask you to renew your consent.
11.3 If you ask us to stop contacting you with marketing or fundraising materials, we will stop using your personal data for that purpose but will keep your contact details on our internal marketing suppression list, needed to ensure we comply with your request.
12. YOUR RIGHTS
12.1 You have the right to obtain confirmation whether we process your personal data, and, where that is the case, access your personal data and request details of the processing activities that we carry out involving your personal data through making a Data Subject Access Request. To make a request contact us:
Post: LM 13.3.1, The Leathermarket, 11-13 Weston Street, London, SE1 3ER
12.2 You also have the following rights:
12.2.1 to request rectification of personal data that is inaccurate or out of date;
12.2.2 to the erasure of your personal data (known as the “right to be forgotten”);
12.2.3 to restrict our processing of your personal data; and
12.2.4 in certain circumstances, request that your personal data be provided to you in a format that is secure and suitable for re-use (known as the “right to portability”).
12.3 All of these rights are subject to certain exemptions and restrictions set out in data protection law. To exercise any of these rights, you should contact us at:
Post: LM 13.3.1, The Leathermarket, 11-13 Weston Street, London, SE1 3ER
12.4 If you are not happy with how we have processed your personal data or dealt with your request, you can complain to the Information Commissioner’s Office. Further details about how to complain can be found at https://ico.or.uk/make-a-complaint/.
Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of that website. Many cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer. Although they do identify a user’s computer, cookies do not personally identify users.
- Essential session management:
- Recognising when a visitor to the website has visited before; means we can identify the number of unique visitors we receive to the website and allows us to monitor progress as well as make sure we have enough capacity for the number of users that we get.
- We may also log information from your computer including the existence of cookies, your IP address and information about your browser program to allow us to diagnose problems and administer and track your usage of the Hub.
- Performance and measurement:
- Collecting statistical information about how our visitors use the website(s) so that we can improve the website(s) and learn which parts are most popular to visitors.
Some of the cookies used by our website are set by us, and some by or with the help of third parties who are delivering services on our behalf. In particular, we use third parties to help us collect performance and measurement statistics about our website.
Most web browsers automatically accept cookies but, if you prefer, you can set your browser to disable cookies or notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.
You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers.
14. EXTERNAL LINKS
The Site may contain links to external websites. We assume no responsibility for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those websites before either agreeing to their terms or using those websites
15. POLICY IMPLEMENTATION, REVIEW AND MONITORING
Responsibility for the implementation of this policy lies with the TRIBE Freedom Foundation Senior Management Team. They are responsible for making the charity aware of the policy, and for its review. This policy will be reviewed every year and at points of significant change to the charity, the Site or the TRIBE Survivor Financial Empowerment Programme.
16. CHANGES TO THIS PRIVACY NOTICE
16.1 This Notice may be revised and updated from time to time. We will advertise any updates on our website and if we make any significant changes, we will contact you directly with the information.
16.2 Please check this Notice when you consider giving us your personal data.
16.3 This Notice was last updated in September 2022
Date of last review: 15 September 2022
Next review due: 15 September 2023