Privacy Policy – Zarah Sultana Campaigns Ltd
This privacy policy informs you how Zarah Sultana Campaigns Ltd will use and protect your personal data. This data is collected, processed and retained for use in political campaigning and associated activities by Zarah Sultana Campaigns Ltd.
1. WHO WE ARE
Zarah Sultana Campaigns Ltd is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).
2. HOW TO CONTACT US
To raise any questions, concerns, or complaints about how your data has been processed, please contact us at info@zarahsultana.com.
3. PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data through:
- your use of this website (including, but not limited to, any data you may provide through this website by, for example, signing-up to our email list); and/or
- engaging with us on third party websites and platforms (including, but not limited to, Typeform, Facebook, WhatsApp, Instagram and Twitter).
By collecting such data, we will be able to inform you about Zarah Sultana’s political campaigning activities.
We may share your data with other campaigns and movements that share the values, principles and aims of Zarah Sultana and which are supportive of our objectives. This will only be done in limited circumstances where we are satisfied that there is a lawful basis to permit such a transfer to take place.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy, together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you. We want you to be fully aware of how and why we are using your data.
This privacy policy supplements other notices and privacy policies (such as wording that may feature on our website alongside options to subscribe to newsletters and other communications) and is not intended to override them.
4. CHANGES TO THIS POLICY
We keep our privacy policy under regular review and will notify you of any substantive changes. Any revisions to our privacy policy can be reviewed on this website.
5. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information from which your individual identity could be discerned. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- identity data, including first name, maiden name, last name, username or similar identifier, title, date of birth and/or gender;
- contact data, including address, email address and/or telephone number(s);
- financial data, including bank account and payment card details;
- transaction data, including details about payments to and from you and other details of products and services you have purchased from us;
- technical data, including 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 and/or third party websites and platforms hosting our content;
- profile data, including your username, your interests, preferences, feedback and/or survey responses;
- usage data, including information about how you use our website;
- aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
6. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you.
Provided by you – directly
You may give us your name and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This also includes personal data you provide when you subscribe to any mailing lists, give feedback and/or contact us directly via such forms, email, telephone or similar mediums.
Third-party sources – indirectly
- Automated technologies or interactions, including cookies: as you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns – where this is strictly necessary to enable the delivery of the website to you, then these cookies will be downloaded automatically. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. You will have the option of declining cookies that are not strictly necessary for the delivery of the website if you do not wish to provide this kind of data to us.
- Publicly available sources: we may receive personal data about you from public sources where there is a lawful basis for such transfers to take place.
- Relevant third-party sources.
7. HOW WE USE YOUR PERSONAL DATA
The uses
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- Inform and engage you about the campaigning work of Zarah Sultana;
- Inform and engage you with any other campaigns and movements that share the values, principles and aims of Zarah Sultana;
- Manage donations, payments, fees and/or charges;
- Comply with our legal obligations; and/or
- Answer your queries and respond to your questions and/or complaints.
The legal bases
- Where you have specifically consented to a particular use of your data (such as where you have subscribed to receive information about Zarah Sultana’s campaigning activities);
- Where you have entered into a legal agreement with us that necessitates that particular use of your data (such as where you make a payment or donation to us);
- Where it is a necessary lawful basis for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- Where we are obliged to process your data in a particular way by law (for example, if we are required to notify any authority or regulator of the nature or value of your donations).
8. WHEN WE WILL SHARE YOUR DATA
We will never sell your personal data to any other organisation and we will not share your personal data unless it is obvious that this is what we are going to do (such as the signing of a petition). We may share your data:
- With third parties to perform services on your behalf and to help promote the campaigning work of Zarah Sultana by serving you advertisements and content online about Zarah Sultana policies we think you might be interested in and/or other campaigns and movements that share the values, principles and aims of Zarah Sultana. We require all third parties to respect the security of your personal data and to treat it in accordance with the law;
- To enable transfers to take place (where appropriate);
- Where we need to comply with a legal obligation; and/or
- With suppliers who act as our ‘data processors’ and who provide the means of processing financial transactions including, but not limited to Action Network, MailChimp, NationBuilder, Stripe, PayPal and others.
We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. COOKIES
A cookie is a tiny text file that is stored on users’ machines (computers, tablets or mobile devices). We may use cookies – including analytics cookies provided by third party companies – in order to tailor your experience on our site according to the preferences you have specified. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
10. THIRD-PARTY LINKS
This website may include links to third-party websites, platforms, 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 or platforms and are not responsible for their privacy policies or statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
11. INTERNATIONAL TRANSFERS
In order to process your personal data for the purposes outlined in this Privacy Policy, we may need to transfer your data to countries or jurisdictions outside the European Economic Area (EEA). In each case, we ensure that our suppliers provide adequate protection for the rights of data individuals in connection with the transfer of their personal data. Currently, we expect all suppliers to use a standard contractual clause approved by the European Union or be part of the Privacy Shield scheme in the United States.
12. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We will notify you and any applicable regulator of a breach where we are legally required to do so.
13. HOW LONG WE WILL HOLD YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
14. YOUR LEGAL RIGHTS
As a data subject, you have a number of rights in relation to your personal data. The rights you have include:
- request access to the personal data that we hold which relates to you (this is often described as a “subject access request”). You can exercise this right at any time by contacting us at info@zarahsultana.com and telling us that you are making a subject access request.
- request that we correct personal data that we hold about you which you believe is incorrect or inaccurate, or to request we erase personal data if you do not believe that we need to continue retaining it. Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase, we will tell you what that reason is at the time we respond to your request.
- request to stop receiving communications. You can opt-out of communications you receive from us at any time by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications). Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by contacting us at info@zarahsultana.com and telling us which communications you would like us to stop sending you.
- request that personal information you have given your consent for us to use is provided in an electronic format so it can be transferred to another data controller (also known as “data portability”).
15. RIGHT TO LODGE A COMPLAINT
If you are unhappy with the way that we have processed or handled your data then you have a right to complain to the Information Commissioner’s Office (ICO). The ICO is the supervisory body authorised by the Data Protection Act 2018 to regulate the handling of personal data within the United Kingdom.
The contact details for the ICO are:
- Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
- Telephone: 0303 123 1113
Website: https://ico.org.uk/concerns/