Privacy Policy
Why you should read this
We are committed to looking after the data you have given us, making sure it’s used responsibly, and that it is only shared in the ways you expect. Your personal details are in safe hands: we will only use your data to keep you up-to-date on WriteUnite CIC’s projects and ensure any submissions you make are published, and their voice heard. We will never sell your data, and we will never share it without your permission.
This Privacy Policy will tell you how we look after the personal data that you provide to us or we collect from you when you visit our website, regardless of where you visit it from. This Privacy Policy tells you about your privacy rights and how the law protects you.
Important information and who we are
It’s important that you know who actually holds your personal data. WriteUnite CIC (“WriteUnite”) is a Community Interest Company registered with company no. 13532796. The website is owned, managed and operated by WriteUnite.
WriteUnite is the data controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this Privacy Policy).
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Manager (DPM) in the following ways:
Full name of legal entity: WriteUnite CIC
Email address: hello@writeunite.org
Postal address: 99 Western Road, Lewes, BN7 1RS, UK
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Purpose of this Privacy Policy
This Privacy Policy provides information on how WriteUnite collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, make a submission, make a donation or purchase a product.
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 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.
Changes to the Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review. This version was last updated on 28 April 2022.
We may make changes to this Privacy Policy from time to time to time. We reserve the right to make any revised policy effective for personal data we already hold about you as well as any information that we receive in the future. If we make any material changes, we will notify our email subscribers. Your continued use of the website, or further submissions, following any changes to the Privacy Policy signifies your acceptance of those changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include 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 encourage you to read the Privacy Policy of every website you visit.
What personal data do we collect about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. 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 follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. It may also include your job title and place of work.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes 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 our website.
- Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may 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.
If you fail to provide personal data
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.
Third-party services and your personal data
We have a presence on social media sites like Facebook, Twitter, Youtube, Instagram, and LinkedIn. We will use any personal data you provide us (eg, if you contact us via Facebook) as laid out in this policy. We may receive aggregated data, as highlighted above, from social media sites on user interaction with our pages.
As a user of a social media service, you will have provided a range of personal data to that service. See their privacy policies to understand how they might use your personal data.
Third-party personal data that we collect
When you submit work to us on behalf of one or more young people, for example as a class teacher or as a parent, we will ask for personal data for the children who have created each submission.
We need the information requested to comply with our obligations, for example, to accurately recognise the author of work we publish, or to ensure the safety of young people we work with. If you are providing third-party personal data to us, it is your obligation to ensure that the individuals involved understand why we will process and store their information.
How is your personal data collected?
We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Submit work to us;
- Apply to take part in our advisory groups;
- Sign up for email updates;
- Provide a case study or article to us;
- Enter a competition, promotion or survey; or
- Give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical, Profile and Usage Data, for example from analytics providers (such as Facebook and Google);
- Advertising networks;
- Search information providers;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from data brokers or aggregators; and
- Identity and Contact Data from publicly available sources.
How we use your personal data
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:
- where we need to perform the contract we are about to enter into or have entered into with you;
- 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;
- where we need to comply with a legal or regulatory obligation; and
- where we wish to send direct marketing communications to you via email, where you have provided your explicit consent to such processing of your data.
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. Where submissions are made on behalf of a child under the age of 13 years old, we will rely on the consent of their parent or guardian for the processing of their personal data.
When a child’s data is being processed that is 13 years old or above we will generally rely on a legal basis for processing their personal data other than consent, such as for processing the data for our legitimate interests. When relying on this basis, we take responsibility for identifying any risks and consequences of the processing, and put appropriate age related safeguards in place. If consent is relied upon from a child, we make sure that the child understands what they are consenting to, and we do not exploit any imbalance of power in the relationship between us.
You have the right to withdraw consent to such marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Data subject | Purpose of processing / activity | Type of data | Legal basis for processing the data | Retention period |
|---|---|---|---|---|
| Prospective Submitters & Submitters | Sending direct marketing communications about WriteUnite and our work | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Data subject’s consent (b) Necessary for our legitimate business interests | 3 years from initial contact unless consent renewed |
| Submitters | Allowing the submission of work to a Project, and the ongoing administration of the Project | (a) Identity (b) Contact (c) Marketing and Communications | (a) Necessary to fulfil our contractual obligations to the Submitter and Submittee (b) Necessary for our legitimate interests (to hold information confirming Informed Consent from parents/guardians of the Submittees) | 5 years after completion of the project work is submitted to. |
| Children whose work is submitted (submittee) | Allowing the submission of work to a Project, and ensuring any submission is credited accurately | (a) Identity | (a) The consent of the child’s parent/guardian (b) Necessary for ours and the child’s legitimate interests (to process the submission and accurately publish and credit their work) | 5 years after completion of the project work is submitted to. |
| Submitters, potential submitters and customers | To manage our relationship with you which may include (a) Notifying you about changes to our terms or Privacy Policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile | (a) Necessary to fulfil our contractual obligations to the data subject (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how our work has an impact) | 5 years after completion of the project that work was submitted to, or purchased from. |
| Customers | To process and deliver your order of goods and services ordered from us including (a) Managing payments, fees and charges (b) Collecting and recovering money owed to us | (a) Identity (b) Contact (c) Financial (d) Usage (e) Profile (f) Marketing and Communications | (a) Necessary to fulfil our contractual obligations to the customer (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests | 7 years after purchase. |
| Youth Advisory Group members | To administer and manage the Advisory Group (including required and relevant communications, research, the management of any physical or virtual events) | (a) Identity (b) Contact | (a) The consent of the child’s parent/guardian (b) Necessary for the child’s and our legitimate interests (to manage their membership of the Steering Group and enable their active involvement) | 1 year after the end of membership |
| Responsible Adults of Advisory Group Members | To administer and manage the Advisory Group (including required and relevant communications, research, the management of any physical or virtual events) | (a) Identity (b) Contact | Necessary for ours and the child’s legitimate interests (to manage membership of the Steering Group and enable child’s active involvement) | 1 year after child’s membership ends |
| Visitors to our website | To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (b) Necessary to comply with a legal obligation | 3 years after your last visit of our website |
| Visitors to our website | To use data analytics (including segmentation modelling) to improve our website, services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of users for our services, to keep our website updated and relevant, to develop our business and to inform our development strategy) | 3 years after your last visit of our website |
Tailoring your communications
We always want our communications to be relevant, useful and inspiring, to help you understand our work and how you’d like to be involved.
That’s why we ask you upfront if and how you’d like to receive marketing information from us – we know you don’t like receiving unwanted mail or emails, and we don’t want to send them either. We may also use the information you have provided and that we collect about you, such as whether you are a teacher, parent, or young person, to tailor our communication.
If you have made a submission to one of our projects, we will keep you informed of the project’s progress by email over the life of the project. These are classed as ‘service’ communications, and are part of the terms of submission.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing hello@writeunite.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to, or collected by, us as a result of the purchase or provision of any services.
Keeping your data safe
We promise we’ll do all we can to keep your data safe. We will store your data securely, encrypt it when we share it, and only hold it for as long as we need to. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a clear need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
How and why we would share your personal details
First of all, we’d like to make a promise. We will never sell your information to anyone, and we will only share it with a partner organisation if you've given us explicit permission to do so or if it is necessary for the performance of the contract that you have with us (e.g. in order to publish your submission). That means you won't end up with junk emails when you trust us with your personal data.
When we have to share your details
We may share your personal data with the parties set out below for the purposes set out in the table above.
So that we can meet our obligations to you, such as send you a book you have ordered, we will pass your personal details onto our suppliers as we need to. This allows them to meet your requests, and that they can get in touch if you need assistance.
Some of these suppliers will be outside the UK. We require all of our suppliers outside the UK to work to the same data standards we do.
In addition to the above, we may also share your personal data with the following third parties in the following circumstances:
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
- to enforce or apply the Terms and Conditions or to investigate potential breaches; and/or
- to protect the rights, property or safety of WriteUnite, our customers, supporters or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
International transfers
As outlined in the table below, some of our suppliers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection to your personal data to the standards of the UK GDPR.
In some instances we use contracts with our suppliers to set out the terms in which we will share personal data.
| Supplier | Activity | Data location |
|---|---|---|
| Squarespace | Website hosting | Outside the UK |
| Google Analytics | Website analytics | Outside the UK |
| Stripe | Payment systems | Outside the UK |
| Mailchimp | Email marketing | Outside the UK |
| Jotform | Website forms | Outside the UK |
How long will you use my personal data for?
We will only retain your personal data for as long as 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.
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Details of retention periods for different aspects of your personal data are set out in the table above. For further information, please contact us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will contact you to request consent to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Your legal rights
Under certain circumstances, you may have the following rights under data protection laws in relation to your personal data:
- Right to request access to your personal data.
- Right to request correction of your personal data.
- Right to request erasure of your personal data.
- Right to object to processing of your personal data.
- Right to request restriction of processing your personal data.
- Right to request transfer of your personal data.
- Right to withdraw consent.
You should be aware that, in some cases, if you ask us to delete or transfer your personal data, or if you withdraw your consent to processing (other than in respect of direct marketing), this may mean that we will not able to continue to supply you with an ordered book or publication, or that we may not be able to include your submission in a project.
You should also be aware that, once we have published a project in which you’ve submitted work, we may be unable to change any reprints due to the size and complexity of our projects.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Cookies
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 our website may become inaccessible or not function properly.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.
Stay in touch
If you’ve read this and wonder why you’re not receiving any information from us, sign up for our email newsletter? You’ll get regular updates and information on our latest projects, how to get involved yourself, and how young people around the world are using their voices for good.