Introduction
At Tiny Seeds we are committed to protecting and respecting your privacy. This policy applies to all personal data collected by Tiny Seeds under the Data Protection (Jersey) Law 2018. This privacy notice will inform you as to how we look after your personal data.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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.
CONTROLLER
Any questions regarding this policy and our privacy practices should be sent by email to hello@tinyseeds.je.
You have the right to make a complaint at any time to the Office of the Information Commissioner (“OIC”) Telephone: +44 (0)1534 716530, Email: enquiries@dataci.org
Address: Office of the Information Commissioner, 4th Floor, One Liberty Place, Liberty Wharf, La Route De La Liberation, St Helier, Jersey JE2 3NY, the Jersey supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the OIC so please contact us in the first instance.
WHAT DATA WE COLLECT
If you are accessing services we may require information from you that may include your personal contact details, the nature of your query and information that you choose to disclose which is relevant to us providing you with access to our services and the fulfilment of our duties.
If you sign up to receive any communications or information from us, the personal information we collect will include your name, address, email address, telephone number, as well as information relating to your request if applicable.
Identity Data includes first name, maiden name, last name, username or similar identifier, title.
Contact Data includes delivery address, email address and telephone numbers.
WHERE AND WHEN WE COLLECT YOUR DATA
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, contact and/or 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:
• subscribe to or request our services or publications;
• make a donation to us; or
• give us some feedback.
FOR WHAT PURPOSES 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 when you have applied for our services.
• where we need to comply with a legal or regulatory obligation;
• process information requests that you have submitted;
• carry out our obligations arising from you accessing our services and programmes;
• deal with event invitations;
• seek your views or comments on the services we provide;
• administrate services;
• notify you of changes to our services;
• send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals or other fundraising activities;
• to pass on to supporting agencies who will work with you in the future to ensure you receive the support you require – only with your prior written/email consent.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
WHO HAS ACCESS TO YOUR INFORMATION?
If you are accessing Tiny Seeds services or enquiring about accessing services, your information is disclosed only to those third parties who require your details to fulfil our requirements to you with your prior consent.
We will not sell or rent your personal information to third parties for the purposes of marketing, and we will not share your personal information for others to use in their marketing or fundraising activities.
We may share your personal information with other companies (e.g. subcontractors, suppliers) who provide services on our behalf, including delivering postal mail, sending emails, analysing data and processing credit card payments. We will only provide those companies with the information they need to deliver the relevant service, and we will make sure that your data is treated with the same level of care as if we were handling it directly
We may need to disclose your personal information if required to the police, regulatory bodies or legal advisors.
We will only ever share your data in other circumstances if we have your explicit and informed consent.
THE RIGHT TO BE FORGOTTEN
Under the Data Protection (Jersey) Law 2018 all individuals have the right to have their personal data erased. Individuals can make a request for erasure verbally or in writing and we will respond to this request within one month. The right is not absolute and our legal obligations supersede above the right to be forgotten.
SECURITY PRECAUTIONS AND BREACH POLICY
When you give us personal information, we take steps to ensure that it’s treated securely.
In the event of personal data breaches, we will report directly to Information Commissioner of Jersey within 72 hours of becoming aware of the breach, where feasible. In the case of a high risk breach which affects our clients and donors, we will inform those individuals without undue delay.
LINKS TO OTHER WEBSITES
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
LAWFUL BASIS
Legitimate interests
The processing is necessary for the purposes of legitimate interests pursued by the controller or by the third party or parties to whom the data are disclosed.
Where our processing is based on consent (e.g. for optional newsletter or sports and social activity), you may withdraw your consent by unsubscribing from the service or emailing us. In the case of Social Media you may unfriend, unlike, unfollow, or otherwise remove the connection.
HOW LONG WE HOLD YOUR DATA
We will retain your personal data for as long as necessary to fulfil the purpose for which it was collected.
DATA SHARING AND DISCLOSURE
We do not share your data beyond what is agreed as necessary for the provision or operation of our services to you. Any third parties we engage to process your personal information are obliged to respect the confidentiality of your information.
There are circumstances where we might share anonymised data (not identifying you) for research and analytical purposes.
There are legal and regulatory circumstances where we may be obliged to share data, for example with Court, Police or Regulator.
TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE
If you use our services while you are outside Jersey or the EU, your information may be transferred outside Jersey or the EU in order to provide you with those services.
REVIEW OF THIS POLICY
We keep this policy under regular review and may, at any time, revise this privacy statement. Where there are material changes to this privacy policy we will use reasonable endeavours to update you of these. This policy was last updated in April 2022.
YOUR RIGHTS
You have the right to apply for a copy of the personal data we hold about you and to have any inaccurate personal data about you rectified.
In some circumstances you may also have the right to ask us to erase your personal data or restrict its processing.
Where we process your data for our legitimate interests, you have the right to object to such processing.
Please bear in mind that if you object to processing or withdraw your consent, this may affect our ability to deliver services to you.
Should you wish to discuss the exercise of any your rights, please contact us by emailing hello@tinyseeds.je