Welcome to the Privacy Policy of the Christian Broadcasting Council of the United Kingdom.

CBC respects your privacy and is committed to protecting your Personal data. This “Privacy Policy” will inform you as to how we look after your Personal Data when you visit our website www.cbc.org.uk (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1.              Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how CBC 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, submit a post or link or manage a link or make a donation to CBC[LE1] [CC2] .

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

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.

For the purpose of this Privacy Policy “you” means any third party that accesses this website as an individual person, not a company or legal entity.

Controller

The Christian Broadcasting Council of the United Kingdom [LE3] is the controller and responsible for your Personal Data (collectively referred to as “CBC”, “we”, “us” or “our” in this Privacy Policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise [your legal rights, please contact the data privacy manager 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 privacy manager in the following ways:

Full name of legal entity: The Christian Broadcasting Council of the United Kingdom

Email address: contact@cbc.org.uk

Postal address: 28 Old Park Road, Peverell, Plymouth, Devon, PL3 4PY

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

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 in May 2022.

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, YouTube channels, links, 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 and are not liable for these third-party websites and their content and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.              The data we collect about you

“Personal Data” 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 as follows:

·       Identity Data includes first name, last name, username or similar identifier

·       Contact Data includes billing address, delivery address, email address.

·       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 this website.

·       Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, links submitted, 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 our third parties and your communication preferences.[LE4] 

·       Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs[LE5] [CC6] , sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 products 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 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:

·       apply for our products or services;

·       create an account on our website;

·       subscribe to our service or publications;

·       request marketing to be sent to you;

·       submit a post or link to upload;

·       enter a competition, promotion or survey; or

·       give us feedback or contact us.

·       Automated technologies or interactions. As you interact with our website, we will 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.

·       Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a)        analytics providers such as Google based outside the EU;

(b)        advertising networks [such as [NAME] based [inside OR outside] the EU[LE7] [CC8] ]; and

(c)        search information providers such as Google based outside the EU.

·       Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based inside the EU[LE9] .

·       Identity and Contact Data from data brokers or aggregators [such as [NAME] based [inside OR outside] the EU].[LE10] 

·       Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4.              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 for products or services, including donations.

·       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 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.

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.

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have opted in to receiving that marketing or newsletter.

Third-party marketing

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time[LE11] ].

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, product/service experience, donations or other transactions.

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 this website may become inaccessible or not function properly.

“Cookies” are data files that are placed on Your device or computer and often include an anonymous unique identifier. For more information about Cookies, and how to disable cookies, visit http://www.allaboutcookies.org. 

We use the following cookies:

●               Strictly necessary Cookies.

These are Cookies that are required for the operation of this website. They are necessary for the safety, security and integrity of the website. For example, they help support the structure of the website pages that are displayed to you, help to improve navigation and allow you to return to website pages you have previously visited. This type of Cookie only lasts for the duration of the time you are visiting the website. When you leave the website, they are deleted automatically.

●               Performance Cookies or analytical Cookies.

They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. We use the “_ga” Cookie which links our visitors use of the website to Google Analytics, this Cookie only lasts for 24 hours from the use of the website. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.

●               “Functionality Cookies”

These are used to recognise you when you return to the website. This enables us to personalise the content for you, greet you by name and remember your preferences (for example, your choice of language or region). These Cookies will remain on your device until you choose to clear it. If you choose to do this, you will need to enter your details each time you visit the website.

●               “Log files”

These track actions occurring on the website, and collect data including Your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps.

·                “Web beacons”, “tags”, and “pixels”

These are electronic files used to record information about how you browse the website. 

·                “Token”

This will be used for authorization for our third party payment platform [PayPal] [LE12] [CC13] as detailed in Clause 16.

Any data collected is done so on the website and via Google Analytics[LE14] [CC15] .

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us 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.

5.              Disclosures of your Personal Data

We may share your Personal Data with the parties set out below for the purposes set out in the table in Clause 4 “Purposes for which we will use your Personal Data” above.

·         Internal Third Parties as set out in the Glossary below.

·         External Third Parties as set out in the Glossary below, with your express consent.

·         Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners will be legally bound to  use your Personal Data in the same way as set out in this Privacy Policy.

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.

6.              International transfers

Correspondence and records are stored on a third party database system.

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries. 

Where we use providers based in the US, we may transfer the Personal Data to them on the strict conditions that they abide by Article 49 of GDPR and provide similar protection to data shared between UK and the US.

We will ensure that transfers to these servers or any others where required meet all legal requirements of Data Protection  Legislation.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

7.              Data security

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.

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.

If you want detailed information on how you can protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org  Get Safe Online is supported by HM Government and leading businesses in the UK.

8.              Data retention

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, accounting, or reporting requirements.

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 requirements.

Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Personal Data be deleted.

Even if you request us to remove your Personal Data or we delete your Personal Data, we have a legal right to keep certain elements of the Personal Data on backup or archival media for legal, tax or regulatory purposes. By law we have to keep basic Personal Data information  (including Contact, Identity, Financial and Transaction Data) for six years for tax purposes.

9.              Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to:

·         Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

·         Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

·         Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with Legal Obligation or local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

·         Object to processing of your Personal Data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms.

·         Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

·         Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

·         Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us on contact@cbc.org.uk             

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). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.

10. Glossary

Within this Privacy Policy the following definitions are used:

Comply with a Legal or Regulatory Obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Data Controller means the entity that is responsible for the control and use of the Personal Data as set out in the Data Protection Legislation.

Data Protection Legislation means all legislation and regulatory requirements in force from time to time relating to the use of Personal Data and the privacy of electronic communications, including, without limitation (i) any data protection legislation from time to time in force in the UK including the Data Protection Act 2018 or any successor legislation, as well as (ii) the General Data Protection Regulation ((EU) 2016/679) and any other directly applicable European Union regulation relating to data protection and privacy (for so long as and to the extent that the law of the European Union has legal effect in the UK).

Legitimate Interests means the interest of  in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our Legitimate Interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Personal Data means any Personal Data that you provide to us as defined in the Data Protection Legislation.

Privacy Policy means this Privacy Policy as amended from time to time.

THIRD PARTIES

Internal Third Parties

Countdown Creative Ltd acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake reporting.

External Third Parties

·       Service providers acting as processors based in the UK who provide IT and system administration services.

·       Professional advisers acting as processors or joint controllers including legal advisers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

·       HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

·       PayPal [LE16] [CC17] acting as processors based inside the EU who provide online payment and finance system and system administration services. PayPal’s privacy policy is here https://www.paypal.com/uk/webapps/mpp/ua/privacy-full

·       Where you grant use consent to send you marketing, we use MailChimp[LE18] [CC19]  (whose privacy policy is here www.mailchimp.com/legal/data-processing-addendum/) whose servers are based in the USA and provide a platform for electronic communications.  Where we use providers based in the US, we may transfer the Personal Data to them on the strict conditions that they abide by Article 49 of GDPR and provide similar protection to data shared between UK and the US. We will ensure that transfers to these servers or any others where required meet all legal requirements of Data Protection  Legislation.

11.           GENERAL

You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy at our sole discretion as set out in this Privacy Policy.

If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted or amended, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

Nothing in this Privacy Policy is intended to, or shall be deemed to, establish any partnership, joint venture or contract of employment between any of the parties.

Each party confirms it is acting on its own behalf and not for the benefit of any other person.

We reserve the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of this Privacy Policy on your first use of the Website following the alterations.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Privacy Policy is governed by and interpreted according to the laws of England and Wales. All disputes arising under this Privacy Policy are subject to the exclusive jurisdiction of the English courts.