We value your privacy. We promise to keep the data you trust us with safe. And we will never share your data with other organisations for their marketing purposes.
Who are we?
The Exchange Inishowen CLG (hereafter referred to as The Exchange) is a charity registered in Ireland (20107857, CHY 21790) and a company limited by guarantee (524171). Our registered address is The Exchange, Castle Avenue, Buncrana, Co Donegal.
We are committed to protecting your privacy and will only use the information that we collect about you lawfully. This policy aims to give you an understanding of how and why we use the information you provide to us both online and otherwise, and covers all of The Exchange’s activities.
What information do we collect and why?
We collect information that is personal data. Personal data is information that can be used to help identify you, such as your name, email address, postal address, telephone number, mobile and telephone number. It also includes Internet Protocol (IP) addresses (the location of the computer on the internet), details of pages visited on our websites and files downloaded.
We collect information in the following ways:
Information you give us directly. For example, when you make a donation, register for an event, enquire about our services or book a room at The Exchange.
Information you give us indirectly. For example, when you make a donation using a third-party platform (such as PayPal). We will select only reputable companies to provide these types of services. If you wish, you can check their privacy policies when you provide your information to understand fully how they will process your data.
Publicly Available Information. We may combine information you provide to us with information available from public sources or records in order to gain a better understanding of those who engage with us. This helps us to improve our resources and programmes. Such information may be found in places such as Companies Registration Office and information that has been published online and in print.
How do we store and protect the information about you?
It is very important to us that any information we hold about you is safe. That’s why we operate to a high level of security in relation to the collection, storage and disclosure of your information.
Information is stored on our Gmail database which is password protected and held on secure servers accessible only by authorised personnel who adhere to this policy. Our computers are password protected and kept in a locked office. We do not hold hard copies of personal information.
How do we use the information about you?
We use the information that we hold concerning you in accordance with the provisions of data protection legislation. We use this information to administer our relationship with you and to provide you with information about our activities.
We may use (or ‘process’) your personal data to:
• Deliver resources, and other materials that you have requested from us;
• Administer your donation;
• Keep a record of your relationship and correspondence with us;
Communicate with you (where we have a legal basis to do so and you have requested us to do so) by post, phone and e-mail for marketing purposes, to provide you with information about us, our fundraising campaigns, our events, products and services, to send invoices and information about your rental of the building and any other information we think may be of interest.
• Manage your communication preferences;
• Comply with applicable laws and regulations, and requests from statutory agencies;
• Further our legitimate charitable aims such as sending you information about how donations are being used or sending you an annual report;
Your Preferences: You can choose at any time which marketing materials you want to receive from and in which format. If there is something you would prefer not to receive, please email us at firstname.lastname@example.org or contact us at The Exchange, Castle Avenue, Buncrana, Co Donegal.
Sensitive Categories: If you provide us with sensitive/special categories of personal data including, but not limited to, your racial or ethnic origin, political opinions, religious or philosophical beliefs or your physical or mental health, we will only use this for the specific purpose for which you gave permission and where it is within our legitimate interests to process or where we have other legal grounds to do so.
Do we share this information with others?
We will not sell or share your personal data with other organisations for their marketing purposes.
We may allow our staff, trainers, professional advisors, consultants and/or external providers acting on our behalf to access and use your information for purposes within our legitimate interest (e.g. to deliver mailings, to analyse data, to process payments and invoices). These data processors have access to personal information needed to perform their functions, but may not use it for other purposes. will select only reputable third parties who will comply strictly with our instructions, with data protection laws, and will make sure that appropriate controls are in place. Third-party data processors being used by at the time of this policy include: PayPal (to process donations) and WordPress (hosting our website).
We may disclose your personal information where we are under a duty in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
What is our legal basis for processing data?
Under the General Data Protection Regulation, there are six lawful bases to process personal data. We rely on a variety of these for using (or ‘processing’) data depending on the purpose for which the data is being processed.
Legitimate interest is about balancing The Exchange’s interests against your interests, rights and freedoms. Basically, it means that when you provide your personal details to us we may use your information for our legitimate interests to carry out our charitable aims and objectives. But before doing this, we will also carefully consider and balance any potential impact on you and your rights. We will not process data in ways that a reasonable person would not expect us to in the circumstances. We rely on legitimate interests for a variety of purposes, which include:
Contacting you via mail or telephone about events or resources which you may be interested in, based on your previous engagement;
• Sending you updates in the post, such as magazines, newsletters, or our Annual Report;
• Saying thank you (by mail or telephone) to you if you make a donation, both at the time of your donation and at other times to communicate our gratitude and to let you know how your gift has made a difference;
• Contacting you via the mail with fundraising appeals and asking for your support based on your engagement with The Exchange’s events, programmes and communications.
Any phone contact will be done by a staff member or volunteer, and not outsourced or automated.
You can let us know at any time if you would prefer not to receive these communications.
We use your consent for all email newsletters and e-appeals delivered by and our programmes. For some electronic communications which involves commercial marketing of products or services (e.g. marketing of our facilities) we will rely on ‘soft opt-in’ e.g. for people who have recently booked the premises, where we believe you will probably be happy to receive marketing about similar products or services. An opt-out will always be provided at the point of collecting your data. We use compliance with a legal obligation as the basis for processing any legally required activities.
How long do we keep your data for?
We will hold your personal data for as long as is needed to fulfil the function for as long as is required by law for the relevant activity (e.g. the Revenue requires us to keep a record of donations and financial transactions for seven years) and for no longer than is necessary for the purposes for which it is processed, in accordance with our internal policies.
What are your rights?
You will always have the right to:
• Request a copy of the information that we hold about you (known as a Subject Access Request). If you would like a copy of some or all of your personal information, please contact us;
• Ask us to correct or remove information you think is inaccurate: we want to make sure that your personal information is accurate and up to date;
• Opt-out of receiving all or some of our marketing communications (as defined by the Information Commissioner’s Office and which includes our newsletters, magazine, campaign updates, appeals and event invitations);
• Request that we stop processing data about you at any time by contacting us;
• Complain. Our complaints policy is set out in full at http://www.exchangeinishowen.ie/wp/about/feedback-and-complaints/
You can contact us at email@example.com, or in writing to our registered address.
Updated on: 12 September 2018