1. Introduction

1.1 This is the privacy policy of Mental Health Matters. Mental Health Matters is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy policy).

1.2 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we handle your personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4 This privacy policy was last updated on 27 September 2021.

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2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).

3. The personal data we collect, how we collect it and how we use it

3.1 In this Section 3 we have set out :

  1. the general categories of personal data that we may process;
  2. the purposes for which we may process personal data; and
  3. the legal bases of the processing.

Type of personal data

Source of personal data

Purpose of processing

Legal basis of processing

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.

This usage data may be processed for the purposes of analysing the use of the website and services.

The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

We may process your account data ("account data"). The account data may include your name and email address.

The source of the account data is you.

The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. 

The legal basis for this processing is consent.

 

We may process your information included in your personal profile on our website ("profile data").  The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, and social media ids.

The source of the profile data is you.

The profile data may be processed for the purposes of enabling and monitoring your use of our website and services.

The legal basis for this processing is consent.

 

We may process [information that you post for publication on our website or through our services ("publication data").

The source of the publication data is you.

The publication data may be processed for the purposes of enabling such publication and administering our website and services.

The legal basis for this processing is consent.

We may process information contained in any enquiry you submit to us regarding products and/or services("enquiry data").

The source of the enquiry data is you.

The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.

The legal basis for this processing is consent.

We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your bank account and payment card details and the transaction details.

The source of the transaction data is you.

The transaction data may be processed for the purpose of recording our fundraising activities and your donation to us, supplying the purchased goods and services and keeping proper records of those transactions.

The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data").

The source of the notification data is you.

The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.

The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence 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.

The source of the correspondence data is you.

The correspondence data may be processed for the purposes of communicating with you and record-keeping.

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.2 We may process any of your personal data identified in the other provisions of this policy 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.

3.3 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of 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.

3.4 Subject to this, 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 receive 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.

3.5 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.6 We may also collect, use and share 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 notdirectly 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

3.7 We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.

3.8 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 the access or information requested). In this case we may have to cancel any services or product we have agreed to provide to you, but we will notify you if this is the case at the time.

4. How your personal data is collected

4.1 We use different methods to collect data from and about you including through:

4.1.1 Direct interactions: You may give us your account, profile, publication, enquiry and transaction data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you create an account on our website, subscribe to our publications, request marketing be sent to you, make donations to us, or give us feedback or contact us.

4.1.2 Automated technologies or interactions: As you interact with our website, we will automatically collect usage data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy below for further details.

4.1.3 Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources: analytics providers such as Google based outside the UK and, providers of technical, payment and delivery services such as Stripe based outside the UK.

5. Providing your personal data to others

5.1 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.

5.2 We may disclose your personal data to any member of our group of companies (this means our subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

5.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

5.4 Financial transactions relating to our website and services may be handled by our payment services provider, Stripe. Transaction data will be processed by our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices at https://stripe.com/gb/privacy).

5.5 Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the follow will apply:

  • Your data will be made available to our website provider
  • The data that may be available to them include any of the data we collect as described in section 3 above.
  • Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
  • They will store your data for a maximum of 7 years.
  • This processing does not affect your rights under section 9 of this privacy policy

5.6 We may disclose your personal data to 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 may use your personal data in the same way as set out in this privacy

5.7 In addition to the specific disclosures of personal data set out in this Section 5, we may also 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.

5.8 We do not transfer your data to any other third party, or transfer your data outside of the EEA.

6. Data security

6.1 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.

6.2 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.

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 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, including or the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

7.3 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, regulatory, tax, accounting or other requirements.

7.4 We will retain and delete your personal data as follows:

  1. usage data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems;
  2. account data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems;
  3. profile data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems;
  4. publication data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems;
  5. enquiry data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems;
  6. transaction data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems;
  7. notification data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems; and
  8. correspondence data will be retained for a period of 7 years, at the end of which period it will be deleted from our systems;

7.5 Notwithstanding the other provisions of this Section 7, 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. We may also retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8. Amendments

8.1 We may update this policy from time to time by publishing a new version on our website.

8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3 We may notify you of changes to this policy by email.

9. Your rights

9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.2 Your principal rights under data protection law are:

  1. the right to access;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  8. the right to withdraw consent.

9.3 Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. In addition, we may also 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. You can access your profile data and adjust your privacy settings by visiting https://www.mhm.org.uk/my-details when logged into the website.

9.4 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.

9.5 Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

9.6 Right to erasure: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

9.7 Right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.8 Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

9.9 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

9.10 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

9.11 Right to data portability: To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9.12 Right to complain: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance.

9.13 Right to withdraw consent: To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.14 You may exercise any of your rights in relation to your personal data by written notice to us at Data Protection Officer, Avalon House, St Catherine’s Court, Sunderland Enterprise Park, Sunderland SR5 3 XJ, by telephoning us on 0191 516 3500, by using the online request form on our website, or by emailing us at [email protected], in addition to the other methods specified in this Section 9.

10. Third party websites

10.1 Our website includes hyperlinks to, and details of, third party websites.

10.2 This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them. If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data

10.3 We operate a number of social media pages (including Facebook and Twitter). Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

11. Personal data of children

11.1 Our website and services are targeted at persons over the age of 16.

11.2 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.

12. Updating information

12.2 Please let us know if the personal information that we hold about you needs to be corrected or updated.

13. About cookies

13.1 Our website uses cookiesto distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

13.2 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.

13.3 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.

13.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

14. Cookies that we use

14.1 We use the following cookies:

14.1.1 Strictly necessary cookies: These are cookiesthat are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, or make use of payment services.

14.1.2 Analytical or performance cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

14.1.3 Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

14.1.4 Targeting cookies: These cookiesrecord your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests.

14.2 We use cookies for the following purposes:

  1. authentication - we use cookies to identify you when you visit our website and as you navigate our website;
  2. status - we use cookies to help us to determine if you are logged into our website
  3. personalisation - we use cookies to store information about your preferences and to personalise the website for you;
  4. (d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  5. (e) advertising - we use cookies to help us to display advertisements that will be relevant to you;
  6. (f) analysis - we use cookies to help us to analyse the use and performance of our website and services; and
  7. (g) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally

Details of the cookies in use on our website, and the dates after which non-essential cookies expire, are available to download here.

15. Cookies used by our service providers

15.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

15.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. This data may be stored outside the EU, under a EU-US Privacy Shield agreement. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/ . The relevant cookies are: ga, _gid, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv.

16. Managing cookies

16.1 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 however obtain up-to-date information about blocking and deleting cookies via these links:

  1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
  2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
  3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
  5. https://support.apple.com/kb/PH21411 (Safari); and
  6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16.2 Blocking all cookies will have a negative impact upon the usability of many websites.

16.3 If you block cookies, you will not be able to use all the features on our website.

17. Our details

17.1 This website is owned and operated by Mental Health Matters.

17.2 We are registered in England and Wales under registration number 01786914, and our registered office is at Avalon House, St Catherine’s Court, Sunderland Enterprise Park, Sunderland SR5 3XJ.

17.3 Our principal place of business is at Avalon House, St Catherine’s Court, Sunderland Enterprise Park, Sunderland SR5 3XJ.

17.4 You can contact us:

  1. by post, using the postal address given above;
  2. using our website contact form;
  3. by telephone, on the contact number published on our website from time to time; or
  4. by email, using the email address published on our website from time to time.

18. Data protection officer

18.1 We have appointed a data protection office who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the data protection officer.

18.2 Our data protection officer's contact details are: [email protected] or 0191 516 3500.

19. Data protection registration

19.1 We are registered as a data controller with the UK Information Commissioner's Office.

19.2 Our data protection registration number is Z6769210.

20. Complaints

20.1 If you consider that we have not used your personal information in accordance with data protection law, you have the right to complain to the Information Commissioner's Office (otherwise known as "the ICO"). The ICO can be contacted on 0303 123 1113 or by visiting their website at www.ico.org.uk.