Privacy Policy

1. Introduction

1.1 In this policy, "we", "us" and "our" refer to St David’s Hospice Care (Charity No. 1010576). For more information about us, see Section 12.

1.2 We are committed to safeguarding the privacy of our website visitors and customers. In this policy we explain how we will handle your personal data.

1.3 This website is not intended for children and we do not knowingly collect data relating to children.

1.4 It is important that you read this privacy policy together with any other privacy policy or fair processing policy that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.5 This policy applies where we are acting as a data controller with respect to your personal data (as defined in Article 4(1) of the UK General Data Protection Regulation (UK GDPR)); in other words, where we determine the purposes and means of the processing of that personal data.

1.6 We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or wish to exercise your legal rights, please contact the DPO using the details set out below.

1.7 Our data protection officer details:
Email:   dataprotectionlead@stdavidshospicecare.org
Phone:   01633 851051

2. The personal data that we collect

2.1 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How we collect your personal data

3.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal obligation.

   Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us by email: enquiries@stdavidshospice.org.uk or via telephone: 01492 879058.

4. Purposes of processing and legal bases

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

   Purpose/Activity

– To register you as a new customer

   Type of data

1. Identity
2. Contact

   Lawful basis for processing including basis of legitimate interest

– Performance of a contract with you

   Purpose/Activity

– To process and deliver your order including:

1. Manage payments, fees and charges
2. Collect and recover money owed to us
3. Any other legal claims

   Type of data

1. Identity
2. Contact
3. Financial
4. Transaction
5. Marketing and Communications

   Lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you
2. Necessary for our legitimate interests (to recover debts due to us)

   Purpose/Activity

1. To manage our relationship with you which will include:
2. Notifying you about changes to our terms or privacy policy
3. Asking you to leave a review or take a survey

   Type of data

1. Identity
2. Contact
3. Profile
4. Marketing and Communications

   Lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

   Purpose/Activity

   – To enable you to partake in a prize draw, competition or complete a survey

   Type of data

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and Communications

   Lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you
2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

   Purpose/Activity

   – To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

   Type of data

1. Identity
2. Contact
3. Technical

   Lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
2. Necessary to comply with a legal obligation

   Purpose/Activity

   – To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

   Type of data

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and Communications
6. Technical

    Lawful basis for processing including basis of legitimate interest

   – Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

   Purpose/Activity

   – To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

   Type of data

1. Technical
2. Usage

   Lawful basis for processing including basis of legitimate interest

   – Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

   Purpose/Activity

   – To apply and administer for gift aid

   Type of data

1. Identity
2. Contact

   Lawful basis for processing including basis of legitimate interest

   – Necessary for our legitimate interest to apply for gift aid.

    Purpose/Activity

   – To make suggestions and recommendations to you about goods or services that may be of interest to you

   Type of data

1. Identity
2. Contact
3. Technical
4. Usage
5. Profile
6. Marketing and Communications

   Lawful basis for processing including basis of legitimate interest

   – Necessary for our legitimate interests (to develop our products/services)

   Purpose/Activity

   – To publish such data on our website and elsewhere through our services .

   Type of data

1. Identity
2. Contact

   Lawful basis for processing including basis of legitimate interest

   – Consent

   Purpose/Activity

   – To create and maintain our databases, back-up copies of our databases and our business records generally

   Type of data

1. Identity
2. Contact
3. Technical
4. Usage
5.  Profile
6. Marketing and Communications

    Lawful basis for processing including basis of legitimate interest

   – Necessary for our legitimate interest to ensure our systems are appropriately backed up.

   Purpose/Activity

   – Security and prevention of crime and other criminal activity.

   Type of data

1.  Identity
2. Contact
3. Usage

    Lawful basis for processing including basis of legitimate interest

   – Necessary for our legitimate interests, namely the protection of our website, services and business, and the protection of others.

   Purpose/Activity

   – Insurance and Risk Management

   Type of data

1. Identity
2. Contact
3. Usage

   Lawful basis for processing including basis of legitimate interest

   – Necessary for our legitimate interest to carry on our business.

5. Providing your personal data to others

5.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

5.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.3 Your personal data held in our website database will be stored on the servers of our hosting services providers.

5.4 Financial transactions relating to our website and services may be handled by our payment services providers, Stripe, We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/gb/privacy.

5.5 In addition to the specific disclosures of personal data set out in Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. International transfers of your personal data

6.1 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.2 Many of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer outside of the UK.

6.3 Wherever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afford to it by ensuring at least one of the following safeguards are implemented.

6.4 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Retaining and deleting personal data

7.1 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.

7.2 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.

7.3 In some circumstances we will anonymise your personal data (so that is can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without notice to you.

8. Security of personal data

8.1 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.

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

8.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8.4 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

9. Third party websites

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

9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Amendments

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

11. Our details

11.1  This website is owned and operated by St David's Foundation Hospice Care.

11.2  We are registered in England and Wales under registered charity number 1010576, registered in Wales number 2700097, and our registered office is at Blackett Avenue, Newport, NP20 6NH.

11.3  Our principal place of business is at Blackett Avenue, Newport, NP20 6NH.

11.4  You can contact us:

1. by post, to the postal address given above;
2. using our website contact form;
3.  by telephone, on the contact numbers published on our website; or
4. by email, using the email addresses published on our website or here: enquiries@stdavidshospicecare.org