Who we are
The processing of your personal data is carried out by or on behalf of JLOF.
JLOF is a registered charity in Sweden & Uganda.
We refer to both organizations throughout this policy collectively as “JLOF” or “we”.
HOW CAN YOU CONTACT US?
By using our website, our social media pages (such as Facebook, Twitter, YouTube and Instagram), subscribing to our services, donating to us and/or shopping online, you agree that, unless you have set your computer’s browser to reject them, we can place the types of cookies set out below on your device and use that data in accordance with this policy.
HOW DO WE COLLECT YOUR INFORMATION?
We may collect information about you directly whenever you interact with us. For example, when you contact JLOF regarding our activities, register as a supporter, send or receive information, engage with our social media or make a donation to us, you may provide us with your personal information.
We may also receive information about you when you interact with third parties with whom we work. For example, where you’ve made a donation to us through a third-party website (e.g., RED or Global Giving) and given them permission to share your information with us.
We may supplement what we know about you with information that is available to the public. For example, in order to ensure that our communication with you is relevant and tailored to your background and interests, we may collect information about you from publicly-available sources either directly or through third-party subscription services or service providers. See ‘How will we combine and analyse the information we collect about you?’ for more detail. We may also carry out research using publicly available information to identify individuals who have an affinity to our cause but with whom we are not already in touch.
Who we share your data with
Suggested text: If you request a password reset, your IP address will be included in the reset email.
WHAT INFORMATION DO WE COLLECT?
The information we collect from you directly or from third parties with whom we work, may include:
bank account details for setting up a regular direct debit,
credit card details for processing credit card payments,
employer details for processing a payroll gift,
taxpayer status for claiming Gift Aid,
date of birth or age to confirm you are over 18,
gender, where appropriate (e.g., where registering for an event, such as a race).
We may also collect and process information about your interactions with us, including details about our contacts with you through email, SMS, post, on the phone or in person (i.e., the date, time, and method of contact), details about donations you make to us, events or activities that you register for or attend and any other support you provide to us. We may also collect and record any other relevant information you share with us about yourself, including your interests or your affiliations with other charities, community groups, your employer or a JLOF corporate partner. If you are a minor, we may collect the name and contact details of a parent or guardian and, where appropriate, the name and location of your school.
In order to ensure that our communication with you is relevant and tailored to your background and interests, we may supplement what we know about you with information that is available to the public. This allows us to better understand your interests, preferences, and level of potential engagement and/or donation, so that we can contact you in the most appropriate way and to ensure that we do not send you unwanted communications. The information we collect and process about you from publicly-available sources may include demographic information associated with your postcode or your address and an estimate of your age. We may collect this information ourselves or through third-party service providers. For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.
Where we have identified that you may have the capacity or affinity to support JLOF at a higher level, we may use the information we hold about you to identify connections between you and our existing circle of key supporters. We may review other information about you that is available to the public through internet searches, social networks, such as LinkedIn, subscription services, news archives or public databases (e.g., Companies House, the electoral, political and property registers), such as information about corporate directorships, shareholdings, published biographic information, employment and earnings, philanthropic interests and networks, charitable giving history and motivations and relevant media coverage, so that we can engage with you in a more personalised way.
DO WE PROCESS ‘SENSITIVE’ PERSONAL INFORMATION?
Under data protection law, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs, and political opinions (‘sensitive personal data’). In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so, such as where we need this information to ensure that we provide appropriate facilities or support to enable you to participate in an athletic event like a marathon.
HOW DO WE USE YOUR INFORMATION?
We may use your information in a number of ways, including:
To provide you with information, products or services that you have requested from us or that we feel may be of interest to you;
To provide you with information about our work or our activities;
To invite you to participate in interactive features on our website;
To process donations we may receive from you;
To fundraise in accordance with our internal policies and procedures;
For administrative purposes (for example, we may contact you regarding an event for which you have registered, to provide information requested from us through Supporter Care or with a query regarding a donation you may have made to us);
For internal record keeping relating to any donations, feedback, or complaints;
To invite you to participate in voluntary surveys or research;
To contact you where you have been identified as a contact person for an organisation, such as a school (if we obtain your contact details in this way, we will only use them to contact you in your capacity as a representative of that organisation unless you have separately indicated that you are happy to be contacted as an individual supporter);
To analyse and improve the content and operation of our website;
To analyse and improve our internal business processes;
To analyse the personal information we collect about you and use publicly available information to better understand your interests, preferences and level of potential donations so that we can contact you in the most appropriate way and to ensure that we do not send you unwanted communications;
To tailor advertising that is presented to you on the Internet according to your interests, preferences and other characteristics (as described below);
To direct advertisements and other communications to other people who may have similar interests or other characteristics to yours (as described below);
To assess your personal information for the purposes of credit risk reduction or fraud prevention; and
Where we are required by law to disclose or otherwise use your information.
In particular, we may contact you for marketing purposes by email or text message if you have agreed to be contacted in this manner. We may also send you service communications via email or text, for example where you place an order for goods or services on our website, or you have made a donation by text.
If you have provided us with your postal address or telephone number, we may send you information about our work or other communications of the kinds described above by direct mail or contact you by telephone unless you have told us that you would prefer not to hear from us in this way. We provide information about how you can change your marketing preferences below.
HOW WILL WE COMBINE AND ANALYSE THE INFORMATION WE COLLECT ABOUT YOU?
In our Supporter Promise, we have committed to communicating with you using an approach that is right for you. This means that we carefully manage the communications we send you to ensure that we are contacting you in the most appropriate way and that we are not sending you unwanted communications. In order to do this, we may combine the information that we collect about you and analyse what we know about your interests, preferences and level of potential engagement or donation. We may also use statistical analysis to analyse this data and understand the likelihood that you will be interested in or responsive to a campaign or message. We may use third party service providers to assist us in this process. For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.
Where we have identified that you have the capacity or affinity to support JLOF at a higher level, we may collect additional information about you (see ‘What information do we collect?’) and combine and analyse that information in a profile of you that will assist us in engaging with you in a more personalised way.
You can opt out of your data being combined and analysed for marketing purposes by contacting our Supporter Care Team or our Data Protection Officer as described below. However, this may mean that you stop receiving marketing communications from us more generally, as we will be unable to determine their relevance to you.
In accordance with our legal and regulatory obligations and our internal policies and procedures, we may also use personal information to carry out due diligence on potential or actual donors. If you opt out of analysis of your data for due diligence purposes, we may not be able to accept donations from you.
HOW WILL WE DISCLOSE THE INFORMATION WE HAVE COLLECTED TO OUTSIDE PARTIES?
JLOF may provide your information to our service providers. Subject to your communication preferences and our internal policies and procedures, this would include providing your information to third parties that work with us to deliver on our charitable purposes, and other entities that act as fundraisers for JLOF, sell JLOF products or provide JLOF with marketing information and services.
Where you have agreed to receive email or SMS marketing communications from us, we may provide your email address or mobile phone number in an encrypted format to social media companies, such as Facebook, Instagram, Twitter or YouTube, or to digital advertising networks that are providing services to us by displaying our advertising to you on those social media platforms and other websites, as well as identifying audiences with interests similar to yours. You can opt out of your data being used to display advertising to you by contacting our Supporter Care Team or our Data Protection Officer as described below. However, this will not prevent our advertisements being shown to you on a randomised basis or based on cookie data and may mean that you stop receiving marketing communications from us more generally.
We enter into contracts with all of these service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.
We will never sell your details. We will only share your details with third parties (who are not service providers working at our direction) as indicated in this Policy or if you have consented or we have another legal basis to do so. We will not make cold telephone calls to members of the general public for individual support and, therefore, will not purchase your data in order to do so.
We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect JLOF, for example in cases of suspected fraud or defamation, or in order to comply with any other applicable legal obligation.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary.
Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk. However, any payment card details (such as credit or debit cards) we receive on our website are passed securely to our payment processing provider according to the Payment Card Industry Security Standards.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will keep and delete your information according to our internal policies and will keep it no longer than reasonably necessary for the purposes for which we hold it, taking into account relevant legal and regulatory retention requirements (e.g. tax or health and safety requirements) and operational considerations.
HOW CAN YOU CHANGE YOUR MARKETING PREFERENCES OR UPDATE THE INFORMATION WE HOLD ABOUT YOU?
In our Supporter Promise, we pledge to make it clear and easy for you to choose how you hear from us. If you do not wish us to use your personal data for marketing purposes as outlined above, you can use the relevant box on the print or online form on which we collect your data or you can follow instructions provided in a print or poster advertisement or in a TV advert to indicate your preference.
You can also change any of your marketing preferences at any time (including telling us that you don’t want us to contact you for marketing purposes) by:
- Indicating that you do not wish to receive our marketing emails by clicking the ‘unsubscribe’ link in at the end of our marketing emails;
- Asking us to stop sending you marketing texts by sending us an “opt-out” text message, following the instructions we provide you in the marketing texts you receive from us;
- Contacting your JLOF contact person;
If you have indicated that you do not wish to be contacted for marketing purposes, we will maintain your details on a suppression list to help ensure that we do not continue to contact you for marketing purposes. However, we may still need to contact you for administrative purposes, including (but not limited to):
- Processing a donation you have made and any related Gift Aid;
- Providing you with the information you need to participate in an activity or event for which you have registered (e.g., a marathon or Christmas Jumper Day); and
- Explaining and apologizing where we have made a mistake.
Similarly, if your contact details have changed or you think any information we have about you is incorrect or incomplete, you can always update or correct the information we hold about you by contacting us through our Supporter Care team as explained above.
WHAT OTHER DATA PROTECTION RIGHTS DO YOU HAVE?
Under Swedish data protection law, you have certain rights over personal information that we hold about you. These rights are summarised below. Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances.
You can assert your rights, raise a concern, or make a complaint about how we process your personal data by contacting our Data Protection Officer or our Supporter Care team. It will assist us, if you explain your request or concern and describe the personal information you are referencing as specifically as possible. In order to action your request, we may need to request further information or request that you provide proof of identity.
Your rights in relation to our processing of your personal information, include:
Right to object to the processing of your data – you have the right to object to our processing of your personal data in certain circumstances. If you object, please explain your objection and the reason for it. If you are objecting to the processing of your data for direct marketing purposes, you can tell us in any of the ways described in the section ‘How can you change your marketing preferences or update the information we hold about you?’ above and we will stop processing your data for those purposes as soon as reasonably possible.
Right to have inaccurate or incomplete personal information corrected or completed – if you believe our records of your personal information are inaccurate or incomplete, you have the right to ask us to correct or complete those records. You can do this as described in this section or in the section ‘How can you change your marketing preferences or update the information we hold about you?’ above.
Right to restrict processing – in certain circumstances, you have the right to ask us to stop making active use of the personal information that we retain in our records about you, if there is disagreement about its accuracy or legitimate usage.
Right of erasure – in certain circumstances, you have the right to request that we delete your personal information from our records.
Right of access – you can write to us to ask for confirmation of what information we hold relating to you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exceptions that apply.
Right to receive your personal information in a portable format – in limited circumstances, where we are processing information you provided to us because you gave us your consent or because it is necessary for the performance of a contract and the processing is carried out by automated means, you may ask us to provide it to you in a portable format.
If you are not happy with how we have handled your request or complaint, you can contact the Office of the Information Commissioner, which oversees the protection of personal data in Sweden.
Alternatively, you may choose to contact the Information Commissioner directly about your complaint, regardless of whether you have raised it with us first.
WHY ARE WE ALLOWED TO PROCESS YOUR PERSONAL INFORMATION?
Our Privacy and Cookie Policies take into account several laws, including:
- the Data Protection Act 2018
- the Privacy and Electronic Communications (EC Directive) Regulations 2003
- General Data Protection Regulation (EU) 2016/679
Generally, our processing of your personal information as described in this policy is allowed by these laws based on one or more lawful grounds, including:
- Where you have provided your consent to us using your personal information in a certain way. For example, we only use your information to send you marketing communications by email or text with your consent. We also may ask for your explicit consent if you share sensitive personal information with us.
- Where the processing is reasonably necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract. For example, we may rely on this basis where you apply to work for us.
- Where the processing is reasonably necessary to comply with a legal obligation to which we are subject. For example, we may rely on this basis where we are obliged to share your personal information with a regulator or HMRC.
- Where the processing is reasonably necessary for the purpose of a legitimate interest pursued by us or a third party and your privacy rights do not override the legitimate interest. Our “legitimate interests” include pursuing the aims and ideals of JLOF through advocating and campaigning for the welfare of children, supporting children and families through our work in the Swedish and globally, and fundraising through direct marketing campaigns, emergency appeals, special events and our retail shops. However, “legitimate interests” can also include your interests, such as when you have requested information from us, and those of third parties, such as our beneficiaries.
For example, we rely on legitimate interests for activities such as sending marketing communications by post or telephone unless you have told us that you would prefer not to hear from us in this way, contacting you as a representative of an organisation about charity partnerships or in order to organise an event, and analysing your interaction with us to improve our internal business processes.
In any event, where we are relying on legitimate interests to process your personal information, we will consider any potential impact on you (positive or negative), your rights under data protection laws, and will not use your personal information for activities where the impact on you overrides the legitimate interests in the processing.
Where we process sensitive personal data (as mentioned above), we will make sure that we only do so in accordance with one of the additional lawful grounds for processing that type of data, such as where we have your explicit consent or you have made that information manifestly public.
JOB AND VOLUNTEER APPLICANTS AND CURRENT AND FORMER EMPLOYEES
You will receive a separate Privacy Statement from us when providing information for these purposes.
YOUR CREDIT OR DEBIT CARD INFORMATION
If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your card details securely to our payment processing partner as part of the payment process. We do this in accordance with the Payment Card Industry Security Standard (PDF download), and don’t store the details on our website or databases.
When you register with us, you are stating that you are 18 years of age or over. You agree that any information you provide to us about yourself upon registration or at any time is true. See Terms and Conditions for more information.
We cannot be held responsible for the privacy of data collected by websites not owned or managed by JLOF, including those linked through our website.
Emails aren’t always secure, and they may be intercepted or changed after they’ve been sent. JLOF doesn’t accept liability if this happens. The contents of emails reflect their author’s views and not necessarily those of JLOF.
Please do not send JLOF any financial data through email.
The information in emails is confidential, so if you’ve received one by mistake, please delete it without copying, using, or telling anyone about its contents.
COOKIES AND HOW WE USE THEM
WHAT ARE COOKIES?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device and to target the content displayed to the user’s interests.
You can find more information about cookies at https://www.allaboutcookies.org and https://www.youronlinechoices.com/uk/
TYPES OF COOKIES
There are two broad types of cookies – ‘first party cookies’ and ‘third party cookies’:
First party cookies are cookies that are served directly by the website operator to your computer, and are often used to recognise your computer when it revisits that site and to remember your preferences as you browse the site. Basically, these are our cookies.
Third party cookies are served by a service provider on behalf of the website operator, and can be used by the service provider to recognise your computer when you visit other web sites. Third party cookies are most commonly used for web site analytics or advertising purposes.
In addition, cookies may be either ‘session cookies’ or ‘persistent cookies’. Your computer automatically removes session cookies once you close your browser. Persistent cookies will survive on your computer until an expiry date specified in the cookie itself, is reached. We use both session and persistent cookies.
CATEGORIES OF COOKIES WE USE
1. Strictly necessary cookies: These cookies are essential for the user to move around the website and to use its features, e.g. shopping baskets and e-billing.
2. Performance cookies: These cookies collect information about how the user makes use of the site, e.g. which pages the user visits most. These cookies do not collect information that identifies the user.
3. Functionality cookies: These cookies remember choices made by or attributes of the user and enhance the features and content you experience during your visit to our website, e.g. language, appeals visited or user’s location. This cookie is also used to remember a user’s preferences for a font size, or customisable parts of a web page.
4. Targeting or advertising cookies: These cookies collect information about the users’ browsing habits. This may also include your use of social media sites, e.g. Facebook, etc. or how you interact with our website which then shows you relevant content elsewhere on the internet. NB. These may also be used to choose the advertisements that are displayed to you on our website and other websites.
WHAT INFORMATION DO WE COLLECT USING COOKIES?
We may collect some, or all, of the information available from cookies when you visit our website, depending on how you use it. We monitor how people use our website so we can improve it. We collect this information anonymously.
However, you can choose to use our website anonymously without giving us any information. Please see ‘Changing your cookie preferences’ below.
- the areas of the website you visit;
- the amount of time you spend on the site;
- whether you are new to the site, or have visited it before;
- the country, region, city and/or borough associated with your IP address or device;
- how you came to our website – for example, through an email link or a search engine;
- the type of device and browser you use;
- how you use the website and the quality of your experience – for example we may track your bandwidth when viewing videos;
- how you interact with our donation and sign up forms – for example what you select as your communication preferences; and
- any error messages that you receive on the site
Although not through cookies, we do measure the success of the emails we send – so we know what subject lines and stories people liked the most. We receive this information anonymously; we don’t share this information.
WEBSITE STATISTICS ANALYTICS, TESTING AND PERSONALISATION
Because we are in a transition period, our website currently uses three types of web analytics services:
1. Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which (as discussed above) are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
You can always opt-out of Google Analytics cookies by Google’s opt-out tool.
You can always opt-out of Adobe Analytics cookies by Adobe’s opt-out tool.
OTHER THIRD-PARTY COOKIES
You may notice some other cookies that are not related to the JLOF’s website whilst visiting www.jlof.net. Some of our pages contain embedded content such as YouTube video, Twitter feed, Facebook likes or Google plus share, and you may receive cookies delivered from these websites. JLOF does not govern the publication of third-party cookies. To understand more about their cookies and privacy statements, please visit the relevant sites.
Some of our cookies will remind you about our work and how you can help after you have left the website. These are the targeting/advertising cookies we use. It is a useful tool for us to keep public awareness of our campaigns and how they can be supported.
If you do not want cookies to be stored on your PC it is possible to disable this function without affecting your navigation around the site.
CHANGING YOUR COOKIE PREFERENCES
The “Help” menu in the toolbar of most web browsers will tell you how to change your browser’s cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. Below is some helpful guidance about how to make these changes.
HOW TO DISABLE COOKIES
If you are using Microsoft Internet Explorer and you wish to block JLOF’s website cookies, you can perform the following:
1. On your browser tools menu, select ‘Internet Options’
2. Click on the ‘Privacy’ tab and then on the ‘Sites’ button
3. Type into the ‘Address of website’ field: www.jlof.net
5. Click on the ‘Block’ button
6. Click on the OK button
Find out more information about blocking or deleting cookies using Microsoft Internet Explorer.
7. Other browsers:
– Firefox cookie management
– Chrome cookie management
– Safari cookie management
Find out more detailed information on disabling cookies.
Last updated: March 2021