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Privacy and cookie policy

Introduction

Welcome to Baby Umbrella's privacy policy. 

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Baby Umbrella 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 use our services or visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. It also provides information on cookies used at the end of this page.

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Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how Baby Umbrella collects and processes your personal data through your use of our services or this website, including any data you may provide when attending our virtual or physical drop-ins, appointments or events, receiving services, or through this website when you make a donation, sign up to our newsletter purchase a product or service, take part in a promotion or competition or email, telephone or otherwise contact us. 

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This website is not intended for children and we do not knowingly collect data relating to children except some information about the babies of those who use our services, for example their age, gender, estimated due date, where and when they were born and name.  We will only collect this from the parent(s) of the baby, or anyone acting on their behalf.

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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. 

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Controller

Baby Umbrella, registered in England and Wales under charity registration 1190745 is the controller and responsible for your personal data (collectively referred to as "Baby Umbrella", "we", "us" or "our" in this privacy policy).

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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. 

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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:

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Full name of legal entity: Baby Umbrella

Email address: legal@babyumbrella.org.uk

Postal address: Baby Umbrella, Data Privacy Manager, 51 The Avenue, Tunbridge Wells, Kent TN2 3FJ

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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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

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Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and reserve the right to modify it at any time, so please review it frequently. This version was last updated on 15/03/2021. 

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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.

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Third-party links

This website may include links to third-party websites, 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 these third-party websites and are not responsible for their privacy statements. 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, or personal information, 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).

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We may collect, use, store and transfer different kinds of personal data about our service users, trustees, supporters, practitioners, subscribers, volunteers and staff which we have grouped together as follows:

  • Identity Data includes first name, last name, marital status, title, date of birth and gender, ethnicity, education level, role and relationship with us.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes where provided bank account and payment card details, and income bracket.

  • 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, 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 purchases or orders made by you, your interests, reasons for  coming to us, preferences, feedback and survey responses.  We might also collect some information about the babies of those who use our services, for example their age, gender, estimated due date, where and when they were born and name.  We will only collect this from the parent(s) of the baby, or anyone acting on their behalf.

  • 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.


We 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 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.

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Special Category Data means personal information relating to someone’s race or ethnicity, political opinions, trade union membership, health, religion, sex life, criminal proceedings or convictions.  The only Special Category Data we collect is ethnicity and health data if this is provided by users of Baby Umbrella services. We do not collect any information about criminal convictions and offences of users of our services but may carry out DBS checks on trustees, employees, practitioners and volunteers.

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, Profile and Financial Data by filling in forms or by corresponding with us in person, by post, phone, online, email or otherwise. This includes personal data you provide when you:

    • enquire about, register for, book, or attend any of our drop-ins, appointments, or other services or events online or offline;

    • apply for or use our services or products;

    • make a donation;

    • subscribe to our service or newsletters; 

    • request marketing to be sent to you;

    • enter a competition, promotion or survey; 

    • apply to become a trustee, volunteer, employee, contractor; 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. We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see the Cookies section below for further details.

  • 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:

      • analytics providers such as Google based outside the EU; 

      • advertising networks; and

      • search information providers.

    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal Giving based inside or outside the EU.

    • Identity, Contact, Financial, and Marketing and Communications Data from booking service Acuity.

    • 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 provide services, products or information requested or to perform a contract we are about to enter into or have entered into with you.

  • Manage payments, donations and other financial transactions, including processing gift aid.

  • Keep a record of our relationships with trustees, supporters, practitioners, service users, volunteers and staff.

  • Keep records relating to any donations, feedback or complaints.

  • Manage communication and marketing preferences and tailor online advertising and fundraising products and opportunities according to someone’s interests, preferences and other characteristics.

  • Provide people with information about us and our work, including fundraising, events and campaigns. We will do this when they have agreed to this or when we have a legitimate interest to do it.

  • Direct advertisements and other communications to people who might have similar interests or other characteristics to our members and supporters.

  • Invite people to participate in surveys and research.

  • Undertake research and equal opportunities monitoring.

  • Report (or use a third party to report) on the services we provide including aggregated personal data and use this to better understand the needs of the users of our services.

  • If you provide us with your child's estimated due date/birth date, we will use this to supply content and offers that are appropriate to your stage of pregnancy or your child's age.

  • 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.

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We might not use your personal information for all of these purposes – it will depend on our relationship with you, and how you interact with our services, website, and activities.

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We might analyse (or use outside services to analyse) our users and supporters’ personal information so that we can better understand the needs of new parents. This could involve carrying out research on the number and characteristics of supporters that live in particular areas, their interests and what they do.

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This helps us to get a better understanding and create profiles of interests and preferences. With this information, we can develop and improve our services, and the way we promote them. We can also better focus our communications and marketing, contacting people with information that is relevant to them.

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Please see the Glossary and Lawful Basis at the end of this page to find out more about the types of lawful basis that we will rely on to process your personal data.

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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.

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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.  You can change your preferences at any time by emailing info@babyumbrella.org.uk and can unsubscribe from marketing by following the opt-out/unsubscribe links on any marketing message sent to you.


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). 

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You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

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Third-party marketing 

We will not share your personal data with any third party for marketing purposes. 

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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 by contacting us at any time at info@babyumbrella.org.uk

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Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of receiving services from us, a product purchase or other transactions.


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. 

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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.

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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 above.

  • External Third Parties as set out in the Glossary.

  • Specific third parties listed in the table Purposes for which we will use your personal data above. 

  • 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 policy. 

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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

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

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Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that where we use certain service providers, we 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.  

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Please contact us at legal@babyumbrella.org.uk  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. 

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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.

8. DATA RETENTION

How long will you use my personal data for?

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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In some circumstances you can ask us to delete your data: see ‘your legal rights’ section below below for further information.


In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

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 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 information 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: 

    • If you want us to establish the data's accuracy.

    • Where our use of the data is unlawful but you do not want us to erase it.

    • 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. 

    • 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.

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If you wish to exercise any of the rights detailed above, please contact us at legal@babyumbrella.org.uk

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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.

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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.

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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. COOKIES

Our website uses cookies to 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.

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A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

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We will use some or all the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

  • 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.

  • 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).

  • Targeting cookies. These cookies record 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 the advertising displayed on it more relevant to your interests.

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You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

  • Facebook Pixel Advertising

  • Acuity/ Squarespace booking system

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You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

11. GLOSSARY

11.1 Lawful Basis

Legitimate Interest means the interest of our business 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.

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Performance of 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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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11.2 Special Category Data 

Special Category Data means personal information relating to someone’s race or ethnicity, political opinions, trade union membership, health, religion, sex life, criminal proceedings or convictions.

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11.3 Third Parties

External Third Parties 

  • Service providers acting as processors such as Google, Acuity/ Squarespace and Paypal (based in the USA) and Wix (based in Israel) who provide cloud hosting, IT and system administration services.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

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