PHOENIX SPACE CIO (referred to as “we”, “us” or “our” in this privacy policy) is committed to protecting the privacy of beneficiaries, donors, supporters, partners and other website visitors to the extent we process personal information.

This privacy policy sets out how we collect, use and store your personal information and your rights in this regard.

1. Contact details

We can be contacted as follows:

Address: Alevtina Nepomniachtchikh, PHOENIX SPACE CIO, 33 Boston Road South, Holbeach, Spalding, Lincolnshire PE12 7LR

Email: info@phoenixspace.org 

1. What data we collect, use, and why

We may collect or otherwise use the following personal information to provide our services to beneficiaries:

• Names and contact details;
• DOB;
• Addresses;
• Email addresses;
• Details of educational requirements;
• Academic history;
• Employment status

We may collect or use the following information in respect of donors and supporters:

• Names and contact details;
• Addresses;
• Email addresses;
• Payment details (including card or bank information for transfers and direct debits);
• Account information, including registration details;
• Transaction data including [details about payments from donors and beneficiaries and other details of donations and support provided].

We may collect or use the following information for donor fundraising purposes:

• Names and contact details;
• Addresses;
• Donor fundraising preferences;
• Website and app user journey information;
• Records of consent, where appropriate.

[We may collect or use the following information for website monitoring purposes and in relation to the use of cookies or similar technologies]:

• Usage Data including information about how users interact with and use our website, products and services.
• Technical Data including internet protocol (IP) address, device ID, browser type and version.
• Subscription and communications data including subscriptions and preferences in receiving communications from us.

3. Purposes and lawful bases for processing personal data

To the extent relevant, we may use the personal information we collect from you when it is necessary for the following purposes:

When we rely on legitimate interests, we make sure we consider and balance any potential impact on your rights and freedoms before we process the personal information for our legitimate interests and do not rely on this lawful basis where your rights outweigh our interest in undertaking the processing.

We always provide you with the choice to opt in to direct marketing from PHOENIX SPACE CIO (which includes email updates, invitations to events, fundraising appeals). Furthermore, data subjects can opt out or withdraw consent from receiving any promotional materials at any time by contacting us by email on info@phoenixspace.org. 

4. Donor fundraising

As part of our major donor fundraising activities we undertake research and profiling of supporters and prospective supporters who may have an interest in, and financial ability to, support our mission.

As explained above, for this reason, we may gather information about donors from publicly available sources – for example, Companies House, the Electoral Register and the media – to help us to understand more about donors and their ability to support the charity. We may also use publicly available sources to carry out due diligence on donors to meet the requirements of anti-money laundering regulations. However, we do not carry out wealth screening and we do not conduct research beyond paywalls.

Carrying out research and processing in this way allows us to conduct high value fundraising, which is essential for our legitimate interests – in this case, our ability to run our grant making programmes. We will always endeavour to do so with great care and in a way that does not unduly impact your rights and freedoms.

You can object to and opt out of your personal information being used for profiling by contacting us at any time by emailing info@phoenixspace.org. 

5. Who may we share your information with?

We may share your personal information with the parties set out below where necessary for the purposes listed above:

• Beneficiaries
• Supporters
• Volunteer staff
• Trustees
• Occasional external consultants
• IT service providers

We may also share your personal information with the following third party service providers:

We may also share personal information with law enforcement or other authorities if required to do so by applicable law.

6. Who may we receive information from?

We may receive information directly from data subjects including :

• Beneficiaries
• Donors
• Supporters

As described above, we may also obtain personal information from some third party sources; for example, in order to conduct due diligence on donors.

7. Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of the personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will normally keep personal information throughout the period of time that we are providing services to you or receiving support from you and afterwards for a period of six years taking account of applicable laws and also the regulations that apply to us.

8. International transfers

We may from time to time transfer your personal data to a country outside of the UK; for example, for the purposes of cloud storage and third party usage.

Where we do so, we will ensure that either:

– the transfer is to a territory subject to an adequacy finding as a matter of UK law (as is the case for example for certain transfers to Ireland or if the transfer falls within scope of the UK Extension to EU-US Data Privacy Framework) or that appropriate safeguards are in place for the transfer of your information outside the UK (for example, the US) such as standard contractual clauses together with any supplementary measures required.

9. What rights do you have?

You have rights in relation to the processing of your personal information:

These are:

• The right to be informed. This means that we must tell you how we use your personal information, and this is the purpose of this privacy policy.
• The right of access. You have the right to access personal information relating you that we hold.
• The right for any inaccuracies to be corrected. If any personal information that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
• The right to have information deleted. If you would like us to stop processing your personal information, you have the right to ask us to delete it.
• The right to restrict the processing of your personal information. You have rights to ask us to `block’ or suppress further use of your information, with certain exceptions..
• The right to portability. You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
• The right to object to processing. You have the right to object to certain types of processing, in certain circumstances. In particular, you have the right to object to the processing of your personal information based on legitimate interests grounds, including automated processing such as profiling.

These are not absolute rights and may be subject to exceptions depending on the context and the reason we are processing your personal information.

If you wish to exercise any of the rights summarised above, please contact us by email on info@phoenixspace.org.

10. Who can you complain to?

If you are unhappy about how we are using your information or how we have responded to a request you have made then we encourage you to first contact us by email info@phoenixspace.org.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/ or https://ico.org.uk/make-a-complaint/. 

11. Changes to this privacy statement
    
    We may amend this privacy policy from time to time.
12. How to contact us

If you have questions about this Privacy Statement or require further information, please contact us by email on info@phoenixspace.org. 

This policy was last updated on 18 October 2024.