At Conservation Without Borders we’re committed to protecting your privacy and security. This policy explains why and how we use your personal data, to ensure you are fully informed and in control of your information.

If you have any questions about this policy please contact:

• Email: Data@Conservation-Without-Borders.org

About CWB

CWB is a charity (1186094 in England and Wales)

The registered address is First Floor Flat, 11 The Square, Chagford, Devon TQ13 8AA

This Privacy Policy relates to personal information (allowing an individual to be identified directly or indirectly) that is obtained and stored by CWB and for which CWB is the Data Controller.

What personal data CWB processes

CWB processes the following types of personal information:

• Identity data, including your title, name, gender and date of birth
• Contact data, including your postal address, email address and phone number
• Financial data, including bank or payment card details
• Transaction data, including details of your giving history
• Marketing data, such as your preferences for receiving communications from us

For individuals we identify as having the potential to support CWB in a further capacity, we may process additional personal information, including:

• Professional information, such as job title(s) and organisation affiliation(s)
• Relevant interests including other charitable giving or activity
• Family information, such as relationships to other CWB supporters
• Wealth information

Please read the section 'Fundraising Research’ below for further information about what personal data we use for Corporate Partnerships, Grants and Major Donor funding research, and how we use it.

Please read the section 'Data Analysis’ below for further information about how we analyse personal data, and how we use it for research and marketing.

How CWB processes personal data

CWB processes personal information in the following ways:

• To administer membership and membership renewals
• To process donations
• To claim Gift Aid on donations
• To confirm receipt of donations, to thank donors and to provide details of how donations may be or have been used
• To enable CWB to maintain a record of supporters’ relationships with the organisation
• To administer legacies
• To carry out research on supporters who we believe may have the interest and ability to support CWB in a further capacity, or individuals who we believe may be prospective supporters of CWB. (See section ‘Fundraising Research’ below).
• To carry out due diligence on donations or pledged donations, where relevant
• For analysis leading to the production of management information relating to income generation and supporter development. (See section ‘Data Analysis’ below).
• In relation to correspondence entered into with CWB by any offline or online channel
• To manage events including the processing of digital tickets
• To implement any instructions CWB receives with regard to withdrawing consent to send information

Individuals can update or withdraw their consent at any time, for individual channels of communication, or for all channels, by contacting CWB’s team by emailing data@conservation-without-borders.org



All CWB’s supporter emails contain an unsubscribe link.

Fundraising Research



CWB relies on the generosity of our supporters to realise our vision of a world where migratory species and their habitats are thriving alongside people. In order to provide the best experience for our supporters while using our charitable resources in the most efficient and effective way possible, we process personal information to carry out fundraising research.

In carrying out this research, we process personal information to identify people who may be interested in supporting our work for the first time or furthering their support for our work. We also process personal information to ensure that the conversations we have with existing and prospective supporters through correspondence and at meetings and events are informed and tailored to each individual and to make a note of these communications and interactions where they are relevant to our relationship with existing and prospective supporters.

CWB may also undertake research to understand areas of our work which existing or prospective supporters may be interested in supporting. Where we do this, we combine any personal information which has been generated through an existing relationship with CWB (e.g. contact and membership details; the amount and purpose of any previous donations) with publicly available information, such as: professional profiles (e.g. corporate biographies or LinkedIn profiles); search engine and public social media results; resources such as Companies House and the Charity Commission; and third-party publications such as the Sunday Times Rich List.

In order to visually recognise supporters who have confirmed their attendance for a specific CWB fundraising event and/or who regularly attend CWB fundraising events, CWB may process images of these supporters which supporters have manifestly made public (e.g. LinkedIn profile pictures) or which supporters have explicitly consented to being made use of by CWB for this purpose. Images processed for this purpose are retained only for the length of time that is necessary for the purpose described above.

Sometimes, we may share personal information about existing and prospective supporters with CWB staff, trustees or other voluntary advocates who are helping us to fundraise. Where this is the case, personal data is only shared with those who need to know the information for the purposes set out in this privacy policy, and only at the time when they need to know it.

In line with Charity Commission regulations and the CWB Gift Acceptance Policy, we also undertake due diligence research, using the above methods, to verify the financial soundness, credibility, reputation and ethicality of donors and prospective donors who have made, or are likely to make, a donation to CWB or who are associated with companies with whom we are exploring a corporate partnership.

If you would prefer to opt out of having your personal information processed in this way, or would like to know more about what our fundraising research and analysis entails, please contact CWB’s team at data@conservation-without-borders.org

Data Analysis

In order to provide the best experience for our supporters while using our charitable resources in the most efficient and effective way possible, we process personal information to carry out data analysis.

In carrying out this analysis, we process personal information to identify people who may be interested in supporting our work for the first time or furthering their support for our work.

Sometimes, we may share personal information about existing and prospective supporters with third parties who are helping us with analysis. Where this is the case, personal data is only shared with those who need to know the information for analysis purposes, and only at the time when they need to know it.

We have created a coding system that identifies particular types of supporters, and this coding has been added to individual supporter records on our database.This will enable us to send more appropriate communications to our existing and potential supporters. This will provide a better experience to these supporters and we hope ultimately will maximise support for conservation.

If you would prefer to opt out of having your personal information processed in this way, or would like to know more about what our data analysis entails, please contact CWB’s team data@conservation-without-borders.org

Your rights

Subject access

Individuals have the right to request at any time the information CWB holds about them, as subject access requests. Such requests should be submitted by emailing data@conservation-without-borders.org

Depending on the nature of the request, CWB may seek a form of identification to verify the identity of the person making it. The information will be supplied within 30 calendar days of the request or the verification, whichever is the later.

Rectification

If individuals believe the information CWB holds about them is incorrect or incomplete, they have the right to ask the organisation to correct it. CWB must respond within one month of the request being received. Requests can be made by contacting CWB’s Supporter Services team data@conservation-without-borders.org

Objection

Individuals have the right to ask CWB to stop processing their personal data. In this situation, CWB can continue to store the data to ensure the request can be respected in the future, but all processing must cease, unless there is a legal purpose. Requests can be made by contacting CWB’s Supporter Services team data@conservation-without-borders.org

Portability

Where they have given consent to CWB processing their data, individuals have the right to ask CWB to provide their personal details to another organisation via commonly used open format such as a CSV file. Requests can be made by contacting CWB’s team data@conservation-without-borders.org

Erasure

Individuals have a right to have personal data erased and to prevent processing by CWB in the following circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
• When the individual withdraws consent
• When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing
• The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
• The personal data has to be erased in order to comply with a legal obligation
• The personal data is processed in relation to the offer of services to a child.

CWB can refuse to comply with a request for erasure where the personal data is processed for legal reasons or other scenarios that may be in the public interest as specified by the ICO.

Erasure requests can be made by contacting CWB’s Supporter Services team data@conservation-without-borders.org

Compensation

If individuals believe they have suffered damage because CWB has behaved in breach of Data Protection law, they are entitled to claim compensation.

This right can only be enforced through the courts.

The law allows CWB to defend a claim for compensation on the basis that the organisation took all reasonable care in the circumstances to avoid the breach, that is, by complying with Data Protection legislation when processing data.

Querying automated decisions

Individuals can ask CWB not to make automated decisions based on their personal data; expect to be advised if the organisation may use automated processes to make such decisions; and challenge the results of automated decisions they believe them to be inaccurate.

Questions and requests regarding automated decisions can be submitted by contacting CWB’s Supporter Services team data@conservation-without-borders.org

Data security

CWB ensures that there are appropriate controls in place to protect personal details provided to the organisation.

CWB’s database is only accessible by approved staff, contractors and suppliers and paper-based information is stored securely as required by GDPR.

Cookies

Cookies are small text files stored on computer by the websites individuals visit. They are standard across all websites and help website owners deliver a better experience to their users.

Further details about managing cookies on all types of devices can be found here: www.aboutcookies.org.

The cookies CWB uses on its website are as follows:

test_cookie

This cookie is set by doubleclick.net. The purpose of the cookie is to determine if the users' browser supports cookies.

__utmc

The cookie is set by Google Analytics and is deleted when the user closes the browser. The cookie is not used by ga.js. The cookie is used to enable interoperability with urchin.js which is an older version of Google analytics and used in conjunction with the __utmb cookie to determine new sessions/visits.

__utmz

This cookie is set by Google analytics and is used to store the traffic source or campaign through which the visitor reached your site.

__utmv

This cookie is set by Google Analytics. The cookie is used to store visitor-level custom variable data and is updated every time data is sent to Google Analytics.

__utma

This cookie is set by Google Analytics and is used to distinguish users and sessions. The cookie is created when the JavaScript library executes and there are no existing __utma cookies. The cookie is updated every time data is sent to Google Analytics.

__utmb

The cookie is set by Google Analytics. The cookie is used to determine new sessions/visits. The cookie is created when the JavaScript library executes and there are no existing __utma cookies. The cookie is updated every time data is sent to Google Analytics.

CWB’s website may at times contain hyperlinks to websites owned and operated by other organisations. These websites have their own Privacy Policies, including policies on their use of cookies. These individual policies will govern the use of any personal information submitted or collected by cookies when individuals visit these websites. CWB cannot accept any responsibility or liability for the privacy practices of third-party websites and the use of such websites is at individuals’ own risk.

Sharing information with others

Suppliers

CWB sometimes uses external companies to process personal data on CWB’s behalf, for example to produce direct marketing materials, process donations, or for analysis purposes.

In these circumstances, with reference to GDPR, CWB is the Data Controller and these suppliers are Data Processors.

The security practices of supplier companies are checked before CWB appoints them and then on a regular basis.CWB puts contracts in place that set out the organisation’s expectations and requirements, especially regarding how suppliers store and process the personal data provided by CWB.

Third party marketing

CWB will only use personal information within the organisation for the purposes for which it was obtained.

CWB will not, under any circumstances, share personal data with any third party organisations for their use or sell it to them for their own marketing purposes, and individuals will not receive marketing communications from any other companies, charities or other organisations as a result of providing their details.

Network mapping

CWB may share personal information about existing and prospective supporters with CWB staff, trustees, trusted supporters or third-party researchers who are helping us to fundraise, including through mapping their networks with their consent. Where this is the case, personal data is only shared with those who need to know the information for the purposes set out in the section Fundraising Research, and only at the time when they need to know it.

Legal requests

CWB will comply with legal requests where disclosure is required or permitted by law and a written request is received, for example, to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime.

Processing within the EU

CWB does not process data outside the EU.

The length of time personal information will be retained

CWB will hold personal information on its systems for as long as it is necessary for it to carry out the relevant activity requested by the individual and as in line with the consent given.

The personal information of individuals who are no longer engaged with CWB will be held for no longer than 7 financial years.This period meets CWB’s statutory obligation to retain information for Gift Aid and other tax purposes.

If an individual asks CWB to cease contact, a record of the request will be kept along with the individual’s personal details to enable CWB to comply with the request over time, but this period will be no longer than the 7 financial years stated above.

Business to business marketing and corporate relationships

CWB is claiming legitimate interest to keep in touch, using their business addresses, with named individual business to business and corporate partnership contacts.This includes new contacts as well as organisations who already had a relationship prior to the introduction of the General Data Protection Regulation on 25 May 2018.

Facebook marketing

CWB may participate in Facebook’s audience matching programme which enables the charity to display adverts to existing supporters when they visit Facebook.

Questions and requests regarding Facebook marketing can be submitted by emailing data@conservation-without-borders.org



Comments or questions about CWB’s Privacy Policy

Any questions about this Privacy Policy should be addressed as follows:

• Email: data@conservation-without-borders.org

The UK's data protection authority is the Information Commissioner's Office (ICO).

The ICO’s website is www.ico.org.uk

The organisation can be contacted at: https://ico.org.uk/global/contact-us/