We are committed to safeguarding the privacy of our website visitors.
This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
In this policy, "we", "us" and "our" refer to Crossways Community. For more information about us, see Section 20.
The personal data that we collect
In this Section 2 we have set out the general categories of personal data that we process.
We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you.
We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use ("service data"). The service data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the service data is you.
We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system Plausible Analytics.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
Purposes of processing and legal bases
In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
Relationships and communications - We may process contact data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries and all of our connected companies) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
Any personal data held in our website database resides on a Microsoft Azure server operated by Crossways Community and located within the EU.
Financial transactions relating to our website and services may be handled by our payment services providers Stripe Payments UK Ltd and Donorbox. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments and dealing with complaints and queries relating to such payments. You can find information about the payment services providers' privacy policies and practices at Stripe Privacy Policy and Donorbox Privacy Policy.
In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
Contact data will be retained for a period of 7 years following the date of the most recent contact between you and us, and will be deleted from our systems at the end of that period;
Service data will be retained for a minimum period of 7 years following the date of the most recent service contact between you and us, and will be deleted from our systems at the end of that period;
Communication data will be retained for a minimum period of 7 years following the date of the communication in question, and will be deleted from our systems at the end of that period;
Usage data will be retained for 7 years following the date of collection;
Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Security of personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
We will store your personal data on secure servers, personal computers, mobile devices and/or in secure manual record-keeping systems.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
Your rights
In this Section 8, we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:
The right to access - you can ask for copies of your personal data;
The right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
The right to erasure - you can ask us to erase your personal data;
The right to restrict processing - you can ask us to restrict the processing of your personal data;
The right to object to processing - you can object to the processing of your personal data;
The right to data portability - you can ask that we transfer your personal data to another organisation or to you;
The right to complain to a supervisory authority - you can complain about our processing of your personal data; and
The right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
Third party websites
Our website includes hyperlinks to, and details of, third party websites.
In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Our website and services are targeted at persons over the age of 18.
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
We use cookies for the following purposes:
Analysis - we use cookies to help us to analyse the use and performance of our website and services; and
Cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
Cookies used by our service providers
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you may not be able to use all the features on our website.
Cookie preferences
Our website does not use cookies therefore cookie control is not required.
Amendments
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
Our details
This website is owned and operated by Crossways Community.
We are registered charity number 1007156 and a Company Limited by Guarantee number 02649197. Our registered office is Administration Building, 8 Culverden Park Road, Tunbridge Wells, Kent TN4 9QX.
Our principal place of business is at Administration Building, 8 Culverden Park Road, Tunbridge Wells, Kent TN4 9QX.
You can contact us:
By post, to the postal address given above;
Using our website contact form (if present);
By telephone, on the contact numbers published on the Contact Us page of our website; or
By email, using the email addresses published on the Contact Us page of our website.
Data protection registration
We are registered as a data controller with the UK Information Commissioner's Office.
Our data protection registration number is Z5575868.
