1. INTRODUCTION

1.1.  We are The Blue Tangerine Charity (a registered charity). Our purpose is to act as a resource for all young people with Special Educational Needs (SEND) including those who attend one of the schools within The Blue Tangerine Federation. We do this by not only organising programmes of education, training and other activities through The Blue Tangerine Charity but by placing our communities at the heart of everything we do.

1.2. Your support (including by fundraising, donating, taking part in our campaigns/events or being a funding partner) enables us to work toward achieving our purpose. When you support us and we engage with you, we will often receive and process your personal information (for example, your name, address and email address).

1.3. We recognise the trust you place in us when you share your personal information with us. We are committed to operating with openness, honesty and transparency.

1.4. In this notice, we provide you with details of the personal information we collect when we engage with you, how we will use and look after your personal information, your privacy rights and how the law protects you.

  1. WHO WE ARE

2.1. The Blue Tangerine Charity is a registered charity in England and Wales (charity number: 1190900).

2.2. We are responsible for looking after your personal information.

2.3. If you have any questions about this privacy notice, including any requests to exercise your rights, please contact us using the contact details set out below.

  1. CONTACT DETAILS

3.1. Our full details if you wish to contact us are:

  • Full name of legal entity: The Blue Tangerine Charity
  • Name or title: Data Protection Officer
  • Email address: [email protected]
  • Postal address: c/o St Luke’s School, Crouch Hall Lane, Redbourn, St Albans, AL3 7ET
  1. THE TYPES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

4.1. Personal information is any information relating to an identified or identifiable individual (“Personal Information”) We may collect, use, store and transfer different kinds of personal information about you, including:

4.1.1. Identity information including your name, gender, date of birth, username, and social media ID’s or similar identifiers.

4.1.2. Contact information including your billing address, delivery address, email address and telephone numbers.

4.1.3. Donation/Transaction information including details about donations you have made and payments to and from you (including bank and credit card information), tax details for Gift Aid and other details of products and services you have purchased from us.

4.1.4. Technical information including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

4.1.5. Profile information including your interests, preferences, feedback and survey responses.

4.1.6. Usage information including information about how you use our website, products and services.

4.1.7. Marketing and Communications information including your preferences for receiving marketing from us and third parties and your communication preferences.

4.1.8. Information about your organisation and its employees and stakeholders including, where applicable, your directors, trustees, office addresses, email addresses, phone numbers and bank details. In some cases, we may need further details such as date of birth or home address of key persons.

4.1.9 Other information you provide when you use our website or participate in our events, surveys, or promotions or when you otherwise interact with us or others on our channels, pages, and accounts on social media and other companies’ platforms.

4.2. We do not generally collect any special categories of Personal Information about you (this 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). If we do collect such data (for example, in order to ensure equity, diversity and inclusion in our supporters), we will strive to collect this in a way where the information you provide is anonymous. There may be occasions where we collect a limited amount of health information (for example, if you take part in any event which requires physical activity, we may ask for certain medical information to ensure you are able to safety participate in the event). We will only collect such health information where we have your explicit consent, or an exception applies under data protection laws.

  1. HOW WE COLLECT YOUR PERSONAL INFORMATION?

5.1. We collect Personal Information in the following ways:

5.1.1. Directly from you – this includes where you donate or fundraise, sign up to one of our events, browse our sites or communicate with us.

5.1.2. Indirectly from third parties’ fundraising sites – this includes the information you have shared with them (for example Just Giving or Virgin Money Giving). These sites may pass your data to us where you have indicated that you wish to support us.

5.1.3. Social Media – we may receive information through your use of social media (for example, Facebook, Twitter and YouTube), depending on your settings or the privacy policy of these social media sites. Please refer to the privacy policies that these sites use for details of how to change your settings.

5.1.5. Third parties – we may receive Personal Information about you from various third parties including technical data from analytics partners like Google, from search engine providers like Bing Webmaster Tools, from technical, payment and delivery service providers like Stripe and lifestyle and demographic insight data from third party segmentation/marketing partners.

5.1.6. Third Party Websites – when you use our websites or otherwise engage with us, you may receive 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 would please encourage you to read the privacy notice of every website you visit as that will govern how that website will process your personal information.

  1. LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

6.1. UK data protection laws (the Data Protection Act 2018 and the UK GDPR (which has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act) require us to have a “legal basis” for processing (using) your personal data. The legal bases we rely on are:

6.1.1. Where we have your specific consent to use your Personal Information for a specific purpose (for example, where we contact you by email).

6.1.2. Where we process your Personal Information for our legitimate interests (or those of a third party). Please see “Legitimate Interests” – below.

6.1.3. Where the processing of Personal Information is necessary to perform a contract with you (for example, where you have purchased a product from us).

6.1.4. Where the processing of Personal Information is necessary to comply with a legal or regulatory obligation that applies to us (for example, in some instances, we may be required to share your information with the Charity Commission, Information Commissioners Office, Fundraising Regulator, other regulators or law enforcement agencies), to use your information for due diligence or ethical screening purpose, or to retain financial records to align with the HMRC’s requirements.

  1. HOW WE USE YOUR PERSONAL INFORMATION

7.1. We will use your Personal Information:

7.1.1. For the provision of services or administration – this may include:

  • Dealing with donations, including communications to confirm and say thank you, for Gift Aid or for other administrative reasons relating to your donation.
  • Dealing with any transaction you enter into with us and for us to fulfil any contract with you (for example, where you purchase from our websites).
  • Managing our events.
  • Dealing with entries into competitions and prize draws and any applicable prizes.
  • Preparing reports about our work, services and events.
  • When you contact us (for example, to ask questions).
  • Administering our websites and monitoring website use (to enable us to improve user experience).
  • Responding to your enquiries, contacts or requests about your Personal Information.
  • Notifying you about changes or updates to the website, our services or our funding processes (as applicable).
  • Displaying content in a device appropriate way (for example, if you are using a mobile).
  • For internal record keeping (we will keep a record of our relationship).

For charitable purposes – for example, to enable us to send you marketing emails or SMS texts where we have your consent.

7.1.2. To contact you by phone where we have your consent.

7.1.3. To send you marketing and fundraising communications by post (or to otherwise engage with you) based on our legitimate interests (or those of a third party). For more information on this, please see “Legitimate Interests” below.

7.1.4. So that we can fundraise effectively and efficiently (for example, by analysing and segmenting our supporters by location, demographics, previous donations or previous activities and to identify your interests and motivations and the level of support you may potentially be able to give to us).

7.1.5. For research and analysis purposes – this may include inviting you to participate in surveys or research or analysing usage data from our website to improve our content or user experience.

7.1.6. For our charitable purposes (for example, where we tell stories to explain our objectives and the work we do).

7.1.8. Carrying out fraud prevention (and money laundering checks), undertaking credit risk activities and in relation to legal claims we take or defend.

7.1.9. To safeguard those who work for or with us (or we otherwise engage with).

7.1.10. To process and administer your application for a job (or to volunteer).

  1. LEGITIMATE INTERESTS

8.1. When we use our legitimate interests as the legal basis for processing your personal information, we will consider and balance any potential impact on you and your rights and freedoms before we process your personal information. We will only then proceed where we believe our interests are not overridden by the impact on you. Our legitimate interests include the interests of our organisation in conducting and managing our operations to enable us to give you the best service and the best and most secure experience, and where we believe it to be in the public interest to process your personal information. Specific examples of this include:

8.1.1. Sending you information and marketing materials to your postal address.

8.1.2. Analysis and profiling of our supporters.

8.1.3. Using third party sources to keep your postal address up to date.

8.1.4. Use of personal information to monitor use of our website (and apps) for technical purposes.

  1. WE RESPECT YOUR PREFERENCES

9.1. If you would like us to stop sending you marketing materials or other communication, please contact us at [email protected].

9.2. You can also unsubscribe from our communications (including marketing communications) by following the directions to ‘unsubscribe’ set out in the communication.

  1. RETENTION PERIODS

10.1. We will generally deem specific consent you have provided us in relation to email marketing materials to be valid for the period of 12 months from your last engagement with us. Where we rely on legitimate interest as the legal basis for contacting you (for example, by post), we may extend this period to 12 months from your last engagement with us. Engagement includes, but is not exclusive to, opening emails, making a donation or other fundraising activity.

10.2. Please note that the periods mentioned in 11.1 are specific to email marketing materials. We may have other reasons to retain related Personal Information (for example, donation data to comply with our financial and legal obligations). In any case, please note that we only keep your Personal Information for as long as we need it to fulfil the purpose we are using it for, as permitted by law.

  1. COOKIES AND OTHER IDENTIFIERS

11.1. A cookie or similar tracking technology is a small piece of text or code sent to your browser or device to help websites and applications remember you and your preferences and collect information about your use of them. 

11.2 You can set your browser to refuse all or some browser cookies and other tracking technologies, or to alert you when websites set or access them. If you disable or refuse cookies and other tracking technologies, please note that some parts of this website may become inaccessible or not function properly.

  1. DISCLOSURES OF YOUR PERSONAL INFORMATION

12.1. We may share your Personal Information with the following third parties set out below:

12.1.1. Payment service providers: If you make a donation or payment on our site, cookies are used by our payment services providers to enable your visit to be identified between page loads, and to make sure that at the payment point only your specific computer can continue with payment.

12.1.2. Google Analytics: We use a service called Google Analytics which collects information about how visitors use our website. We use this information to compile reports and to help us improve the website. The information we collect includes the number of visitors to the website, where visitors have come to the website from and the pages they visited. The information is collected and processed in a way that does not directly identify anyone. Where sites or apps have implemented Google Analytics with other Google Advertising products, like Google Ads, additional advertising identifiers may be collected. Users can opt-out of this using our cookie settings. We rely on consent as our basis for processing and only collect the analytics information if you opt-in to the use of non-essential cookies and similar technology.

12.1.3. Analytics, search engine and marketing/segmentation providers: We may share data with analytics and search engine providers who assist in the optimisation of our site and our services. We also work with marketing/segmentation specialists (who may provide us with lifestyle and demographic insights to enable us to tailor and target our communications).

12.1.4. Professional advisors: Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

12.1.5. HMRC / Other Regulators: Where we are under a legal duty to disclose or share your Personal Information in order to comply with legal obligations, including to HM Revenue & Customs, regulators and other authorities (who require reporting of processing activities in certain circumstances, including in relation to Gift Aid).

12.1.6. Partners: We work with various partners, including suppliers and subcontractors who will process data on our behalf. These suppliers include those who provide us with IT services, system administration, our funding management system and related tools or applications, as well as other services (including market research).

12.1.7. Legal Rights: To enforce and protect our legal rights, or the safety of those who work for us, or with us, our beneficiaries, donors or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

12.1.8. Merger: If we merge (or if we were to sell any part of our operations) including where BTC or its assets are acquired by another charity or other third party, personal data will be one of the transferred assets.

12.2. We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions. Some of our partners run their operations outside of UK and this may include countries who have different data protection laws. We will always take steps to make sure appropriate protections are in place (in accordance with UK data protection law) and that information is safeguarded. This includes ensuring the appropriate transfer mechanisms are in place, such as the relevant third party, having Binding Corporate Rules in place, entering into International Data Transfer Agreements with us or only processing personal data in countries which are subject to an adequacy decision.

  1. CHILDREN

13.1. We will collect Personal Information and engage with you in accordance with this privacy notice, however, please note, if you are under 18, you must have your parent or guardian’s permission before you provide us with any Personal Information. If you are 13 or under, we will also require a parent or guardian’s email address before we engage with you and we will then contact such parent or guardian to verify that we may engage with you (and will typically then collect the parent or guardians’ Personal Information and not that of the child).

  1. DATA TRANSFERS

14.1 Sometimes, our use of your Personal Information requires your Personal Information to be transferred to countries outside the United Kingdom, including countries where the legal protection of your Personal Information may be different. 

14.2 When we transfer your Personal Information outside the United Kingdom, we will ensure that appropriate safeguards are in place (for example, standard contractual clauses) in compliance with applicable law.  

  1. DATA SECURITY

15.1. We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties on a need-to-know basis. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality.

15.2. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. YOUR RIGHTS 

You have the right to access and receive a copy of your Personal Information, to request rectification or erasure of your Personal Information, to request the restriction of processing of your Personal Information, and to object to the processing of your Personal Information. These rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the other laws and regulations to which we are subject. If you would like to exercise your rights, or you have a complaint about the way we process your personal data, you may contact us using the contact details set out in section 3 of this policy.  

You also have the right to make a complaint or raise any concerns you have that relate to our approach to your Personal Information to the Information Commissioner’s Office (ICO – the ICO is the UK regulatory authority for data protection issues (www.ico.org.uk)), although we hope that we can assist with any queries or concerns you may have about our use of your Personal Information. 

  1. CHANGES TO THE PRIVACY NOTICE

17.1. This privacy notice was last updated in May 2024.

17.2. Please note that we may update this privacy notice from time to time and will publish any update on our websites. If we make significant changes to this notice, we will directly inform you of these changes where reasonably practicable (for example, if we have your email address, we will email you).