Privacy Policy

Our commitment to privacy

This privacy policy (‘Privacy Policy’), sets out how The Sparkle Foundation (‘we’, ‘us’ or ‘our’ being interpreted accordingly) uses and protects the personal information about you that we collect or that you provide, whether through our UK website at https://sparklemalawi.org/ (‘Website’) or by other means. You should also check any user terms and conditions from time to time that generally apply to use of this Website.

We aim to collect and process your Personal Data in accordance with the applicable laws that regulate data protection and privacy. This Privacy Notice includes:

• Changes to our privacy policy
• Personal data we collect and how
• Use of your personal data
• Legal bases we rely on for processing your personal data
• Disclosing your personal data to third parties
• International Transfers
• Your Rights
• Security to protect your personal data
• Data Retention
• Cookies
• Contact us
• Complaints
• Governing Law

Changes to our privacy policy

We will modify this Privacy Policy in line with changes or updates made to the relevant data privacy regulations at any time so please check that you have seen the latest version. We will aim to post changes to the practices outlined in this Privacy Policy at least 30 days prior to them being implemented.

This policy was last updated on 04/05/23

Personal data we collect and how

Personal information is referred to in this Privacy Policy as 'Personal Data' and refers to any information relating to an identified or identifiable individual.

The type of personal data we collect includes your name, email address, home (or work) address, phone number and other personal details which you may choose to provide.

Any credit card or debit card data you provide is securely handled by our third-party payment processor (or such other third-party payment processor) as we use from time to time. We never store your credit or debit card details.

We collect personal information from you in various ways, for example:

• if you supply personal information when using this Website;
• when you supply personal details in the course of registering support;
• when you provide personal details in the course of registering as a potential beneficiary or proposing a potential project;
• when you make a donation through our fundraising platforms, Virgin Money Giving, Charity checkout, Just Giving, DonorSee and Stripe in which case they will provide us with this information – see also section headed Third Party Platforms below;
• when you sign-up to receive newsletters or email notifications from us;
• if you order any merchandise; and/or
• if you raise a query or issue with us.

Use of your personal data

We may use your Personal Data for the following purposes:

• providing you with access to our website as well as administering or developing Website features or content;
• fundraising or direct marketing purposes. Where you have expressly consented to us doing so in accordance with applicable law, we may contact you for these purposes by telephone or electronic message (e.g. email or SMS).
• administering any on-going donations or support you provide;
• providing you with news about us or any projects, campaigns, or events that we may be involved in;

We may also contact you for other purposes that you consent to from time to time.

We may process or disclose your Personal Data where it is necessary for compliance with an applicable legal or regulatory obligation to which we are subject to:

• undertake our donor and beneficiary due diligence, and on-boarding checks
• carry out verification, know your client (KYC), terrorist financing, sanctions, and anti-money laundering checks
• comply with requests from regulatory, government, tax and law enforcement authorities
• for surveillance and investigation purposes
• carry out audit checks
• maintain statutory registers
• prevent and detect fraud
• comply with sanctions requirements

We may process or disclose your Personal Data with your consent. If we rely on your consent to process personal data, you have the right to withdraw this consent at any time. Please contact us or send us an email at admin@sparklemalawi.org at any time if you wish to do so.

Legal bases we rely on for processing your personal data

In order to process your personal data, the data privacy regulation requires us to have one or more lawful grounds to do so. The following are relevant to our use if your data:

Consent

We may process or disclose your Personal Data for marketing purposes where you have consented for us to do so in accordance with applicable law.

If we rely on your consent to process personal data, you have the right to withdraw this consent at any time. Please contact us at admin@sparklemalawi.org to withdraw your consent or opt-out of receiving further marketing communications.

Legitimate Interest

We may process or disclose your Personal Data for our legitimate interests or those of a third party (such as a transaction counterparty or a partner to a project) to:

• manage and administer any projects relating to beneficiaries
• assess and process any applications or requests made by you
• send updates, information and notices or otherwise correspond with you in connection with projects
• address or investigate any complaints, claims, proceedings or disputes
• provide you with, and inform you about, our work and opportunities to support us
• monitor and improve our relationships with our supporters and beneficiaries
• assist our transaction counterparties and partners to comply with their regulatory and legal obligations (including anti-money laundering, ‘know your client’ and sanctions checks)
• manage our risk and operations
• ensure appropriate group management and governance
• keep our internal records
• prepare reports on incidents / accidents
• protect against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes (to the extent that this is not required of us by law)
• analyse and manage commercial risks
• seek professional advice, including legal advice
• monitor communications to/from us using our systems
• protect the security and integrity of our IT systems

We only rely on these interests where we have considered that, on balance, the legitimate interests are not overridden by your interests, fundamental rights or freedoms.

Legal Obligation

We may process or disclose your Personal Data where it is necessary for compliance with an applicable legal or regulatory obligation to which we are subject to:

• undertake our donor and beneficiary due diligence, and on-boarding checks
• comply with applicable regulatory obligations including carrying out verification, know your client (KYC) checks, terrorist financing, sanctions, and anti-money laundering checks
• comply with requests from regulatory, governmental, tax and law enforcement authorities
• comply with our accounting and tax reporting requirements
• for surveillance and investigation purposes
• comply with our audit requirements and carry out audit checks
• maintain statutory registers
• prevent and detect fraud
• assist with internal compliance with our policies and processes

Disclosing your personal data to third parties

We never sell, trade, or rent Personal Data. We do not disclose Personal Data to third parties without your consent unless we are legally required to do so or where we need assistance of third-party data processors (acting under our instructions) who we may need to assist us to respond to your enquiry. We will take reasonable steps to ensure that Personal Data is only used by those third parties for specific, lawful purposes in accordance with this Privacy Policy.

International transfers

Given the international nature of our organisation, Personal Data that we collect will be processed by staff, volunteers and contractors who are based at our offices in both the UK and UAE. We may also share your Personal Data with our other offices in other parts of the world in accordance with this Privacy Policy.

Your rights

You have a few different rights that you can exercise in respect of your data where applicable laws allow. These include:

• The right to access all the personal data we hold about you;
• The right to rectify your personal data that may be incorrect, out of data or incomplete;
• The right to delete your personal data from our systems;
• The right to restrict/limit the processing of your personal data and;
• The right to object to the processing of your personal data completely.

In order to exercise any of these rights, please contact the UK Data Protection Officer using the contact details below under 'Contact Us'.

You can exercise any of your rights free of charge, however we may require further information to verify your identity or locate specific information in order to provide a response to your request.

Security to protect your personal data

We employ appropriate technical and organisational security measures to protect Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We also endeavour to take all reasonable steps to protect Personal Data from external threats. However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of all data disclosed or transmitted to us.

Data retention

We will retain certain Personal Data in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which in the UK may be up to 6 years after a particular transaction).

In respect to holding Personal Data for fundraising or direct marketing purposes, we will not retain this data for longer than is necessary for the purpose it was originally collected for.  

Cookies

By using this Website, you consent to us using ‘cookies and similar technologies' that can track your activity. Cookies are small pieces of information sent by a web server to a web browser (e.g. Internet Explorer, Safari, Google Chrome, or Firefox) on the computer or device you use to access this Website, which enables our server to collect information from your device browser.

Enabling some of these cookies is not strictly necessary for the Website to work but it should enable us to provide you with a better browsing experience. Cookies can be deleted or blocked through changing your web browser settings, however some features of the Website may not work as intended and you may not be able to access parts of the Website. The cookie-related information will not be used for personal identification of individuals and data relating to usage patterns on our website is kept under our control. These cookies will used for the following purposes:

• to improve Website usability;
• so we can remember your device or computer between successive actions or sessions; and
• to perform anonymous statistical analysis to improve functionality of our website or any services we offer through the Website.

Please note that when accessing the web and clicking on third party links that may be provided when using our site, those third parties (including, for example, providers of external services that are relevant the Services we offer) may also use cookies on their websites, over which we have no control.

Our website also makes use of Google Analytics and similar or related analytic products to store information that you send to the server when using the Website. This data includes IP address, pages accessed, and documents uploaded, modified, or deleted. For more information about Google Analytics and its privacy practices, please see: https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008.

Contact Us

If you have any queries regarding this Data Privacy Policy or would like to exercise any of your data privacy rights, please contact us at admin@sparklemalawi.org.

Complaints

We will always aim to resolve any concerns you may have in relation to our approach to data privacy. However, if you feel that we have not handled your personal data or rights requests correctly, you are entitled to make a complaint to the UK supervisory authority, the Information Commissioners Office at:

Website: ico.org.uk/make-a-complaint  

Telephone: 0303 123 1113

Governing law

This Privacy Policy is subject to English law. To the maximum extent legally permitted, you agree that any dispute relating to use of your Personal Data as referred to under this Privacy Policy is subject to the exclusive jurisdiction of the courts of England and Wales.