1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.

1.2    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

  1. Credit

2.1     This document was created using a template from SEQ Legal http://www.seqlegal.com which has been amended.

  1. On which basis we collect personal information

3.1    Personal information we hold about you will be collected/used either because:

3.1.1  you have consented or explicitly consented to the use for the specific purposes described in this notice;

3.1.2  the use is necessary in order for us to comply with our obligations under a contract between you and us; or

3.1.3   compliance with a legal obligation;

3.1.4   the use is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in use your personal information which is not overridden by your interests in privacy and security.

  1. Collecting Personal information 

4.1    We may collect, store and use the following kinds of personal information:

4.1.1  information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);

4.1.2  information that you provide to us when registering with our website (including your name, email address and communication preferences.);

4.1.3  information that you provide to us for the purpose of subscribing to our communications (including your name, address, telephone number and email address);

4.1.4   information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);

4.1.5   information relating to any purchases you make of our goods and/or services or any other transactions that you enter into through our website (including your name, address, telephone number and email address);

4.1.6   information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);

4.1.7   information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and

4.1.8   a record of any correspondence between you and us;

4.1.9   replies to any surveys or questionnaires that we may use for research purposes;

4.1.10  any other personal information that you choose to send to us.

4.2    Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

4.3    If we do obtain your personal information from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.

  1. Using personal information

5.1    Personal information submitted to us through our website or provided to us in other ways (e.g. via email or other forms) will be used for the purposes specified in this policy or on the relevant pages of the website.

5.2    We may use your personal information to:

5.2.1    ensure that the content of our website is presented in the most effective manner for you and for your device;

5.2.2    assist in making general improvements to our services;

5.2.3    administer our website and business;

5.2.4    enable your use of the services available on our website;

5.2.5    send you goods purchased through our website;

5.2.6    supply to you services purchased through our website;

5.2.7   send statements, invoices and payment reminders to you, and collect payments from you;

5.2.8    send you non-marketing commercial communications;

5.2.9    send you email notifications that you have specifically requested;

5.2.10    send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);

5.2.11    send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);

5.2.12    deal with enquiries and complaints made by or about you relating to our website;

5.2.13    keep our website secure and prevent fraud; and

5.2.14    verify compliance with the terms and conditions governing the use of our website.

5.2.15    If you have signed up for an event with us we will be contacting you with information, on that event, fundraising tips and training hints;

5.2.16    administer your donations or support your fundraising efforts;

5.2.17    process Gift Aid on donations;

5.2.18    manage your marketing preferences;

5.2.19    review your application to become a volunteer or for a job role;

5.2.20    to assist you with being a volunteer for us;

5.3    If you gave a donation and you said yes (by ticking the box) to our question “Can we contact you again?” we will use your personal information in the following ways:

5.3.1    if you ticked the box next to “via post” we will contact you by post by sending you our annual newsletter and two further appeals for donations per year. If you do not make a donation for over one year, we will stop contacting you via post.

5.3.2    if you ticked the box next to “via email” we will send you our email newsletter. You can unsubscribe at any time by clicking ‘unsubscribe from this list’ which appears at the bottom of every email.

5.4    We do not contact you by telephone for any other purposes aside from administrative matters.

  1. Disclosing personal information

6.1    We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. For example:

6.1.1    where information such as email addresses is passed to those who provide technical support or other services in the provision of our services;

6.1.2    in order to enforce any terms and conditions or agreements for our services that may apply;

6.1.3    All regular donations, i.e. direct debits, are handled through our payment service provider, Stripe. You can review Stripe’s privacy policy at https://stripe.com/gb/privacy All other website financial transactions are handled through our payment services providers, GoCardless and PayPal. You can review GoCardless's privacy policy at https://gocardless.com/legal/privacy/ You can review PayPals privacy policy at https://www.paypal.com/ie/webapps/mpp/ua/privacy-full We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

6.2    We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

6.3    We may disclose your personal information:

6.3.1    to the extent that we are required to do so by law;

6.3.2    in connection with any ongoing or prospective legal proceedings;

6.3.3    in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);and

6.3.4    to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

6.4    Except as provided in this policy, we will not provide your personal information to third parties.

  1. International data transfers

7.1    Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

7.2    Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

7.3    If we transfer your information outside of the EEA in this way, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate information protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

7.4    By submitting your personal information to us you agree to the transfer, storing or use of your information outside the EEA in the manner described above.

7.5    Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

  1. Retaining personal information

8.1    This Section 8 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

8.2    Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

8.3   Please note section 5.3 above on when we stop sending information about donations.

8.4    We will usually delete personal data falling within the categories set out below at the date/time set out below:

8.4.1    Name, email address, telephone number, postal address and communication preferences will be deleted 7 years from the date we received it.

8.5   Notwithstanding the other provisions of this Section 8, we will retain documents (including electronic documents) containing personal data: 

8.5.1    to the extent that we are required to do so by law;

8.5.2    if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

8.5.3    in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

  1. Security of personal information

9.1    We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

9.2    We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

9.3    All electronic financial transactions entered into through our website will be protected by encryption technology.

9.4    You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

9.5    You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

  1. Updates to this Policy

10.1    We may update this policy from time to time by publishing a new version on our website.

10.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

10.3    We may notify you of changes to this policy by email or through the private messaging system on our website.

  1. Your rights

11.1    If you would like to update your personal information or let us know the personal information we hold is incorrect, you may do so on our website here, or by contacting us on the details below. 

11.2    You have the right to know about how we protect your personal information (as set out in this policy). 

11.3    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. However, you always have the right to unsubscribe from our newsletter or any other services where we rely on your consent for holding your personal information. We will ensure you are unsubscribed as soon as possible but within [one month].

11.4    You also have a right to restrict our use of your personal information and the right to object to your personal information being processed please contact us on the details below.

11.5   You have the right to ask us to stop using your personal information in certain ways (as set out in the policy).

11.6    You have the right to ask us to delete your personal information. Unless we have reasonable grounds to refuse to delete your personal information, we will securely delete the personal information in question within one month. [The personal information may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible.]

11.7    You have the right to request access to the personal information that we hold about you:

11.7.1    We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

11.7.2    We may need you to prove your identity and we may need for example to ask for copies of your passport or other identification documents.

11.7.3     If a breach is likely to result in a risk to your information rights and freedoms, we will notify you as soon as possible and we may also report it to the ICO.

  1. Third party websites

12.1    Our website includes hyperlinks to, and details of, third party websites.

12.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

  1. Cookies

13.1    Our website uses cookies.

13.2    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.3    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.4    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

13.5    We use both session and persistent cookies on our website.

13.6    The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:

13.6.1    We use __utma to store the amount of visits of a user, the time of their first visit, the previous visit, and the current visit. It does not contain any personal information and is used only for analytical purposes.  

13.6.2    We use __utmz to store where a user came from (eg. search engine, search keyword, link).

13.6.3  We use _ga and _gid to distinguish between website users in Google Analytics.We use _gat_UA-XXXXXXXX-X (where the Xs are replaced by the Google Analytics ID number) to moderate calls to the Google Analytics service.

13.6.4    We use __unam which is part of the ShareThis service and monitors "click-stream" activity, e.g. web pages viewed, navigation from page to page, time spent on each page etc. The ShareThis service only identifies a user if they have separately signed up with ShareThis for a ShareThis account and given them consent. Checks how long you stay on a site: when a visit starts, and ends. It does not contain any personal information and is used only for analytical purposes.

13.6.5    We use cc_cookie_accept to store whether the user has accepted the cookie message or not.

13.6.6    We use ToggleStatus to store whether the user has hidden or shown the contacts filter search.

13.6.7    We use ASP.NET_SessionId to authenticate a user's session after logging in. Closes when you exit the browser.

13.6.8    We use ARRAffinity which tells our infrastructure which server to handle the request.

13.6.9   We use MemberLoggedIn, a binary flag which stores whether a user is logged in or not.

13.6.10    We use ai_session and ai_user to track users as they navigate the website predominately for infrastructure performance insights. 

13.6.11    We use DisplayName to keep track of a donor’s preference to show their name during a Direct Debit.

13.7    Most browsers allow you to refuse to accept cookies; for example:

13.7.1    in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";

13.7.2    in Firefox (version 47) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and

13.7.3    in Chrome (version 52), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.

13.8    Blocking all cookies will have a negative impact upon the usability of many websites.

13.9    If you block cookies, you will not be able to use all the features on our website.

13.10    You can delete cookies already stored on your computer; for example:

13.11    in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);

13.12    in Firefox (version 47), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and

13.13    in Chrome (version 52), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".

  1. Contact us

14.1    This website is owned and operated by Afghanaid.

14.2    We are registered in England and Wales as a company limited by guarantee with company number 03034888 and as a charity in England and Wales with charity number 1045348 and in Scotland with charity number SC044614 and our registered office is at Afghanaid, The Busworks, Omnibus Business Centre, 39-41 North Road, London, N7 9DP. We also subscribe to the Fundraising Regulator.

14.3    Our principal place of business is at House 25, Street 3, Qala-E-Fatullah, Kabul.

14.4    You can contact us:

14.4.1    by post, using the postal address Afghanaid, The Busworks, Omnibus Business Centre, 39-41 North Road, London, N7 9DP;

14.4.2    using our website contact form;

14.4.3    by telephone, on the contact number published on our website; or

14.4.4    by email, using the email address published on our website.

14.5    If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the ICO by visiting http://www.ico.org.uk/ for further assistance.