Privacy Policy

This privacy policy sets out how SWEF C.I.C. uses and protects your personal data.
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1. Important information and who we are

Privacy Policy

This privacy policy gives you information about how SWEF collects and uses your personal data through your use of this website, including any data you may provide when you apply for a grant with us or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Contact information
Owner and Data Controller
C/O Tozers Llp (Ref Jje)
Broadwalk House, Southernhay West.
Exeter. United Kingdom
EX1 1UA

SWEF C.I.C. is the controller and responsible for your personal data (collectively referred to as “SWEF”), “we”, “us”, or “our” in this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (section 8), please contact us using the information set out in the contact details section (section 9).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, title, date of birth and gender. It may also include your business/company details and your social media profiles
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to you
• 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, device ID and other technology on the devices you use to access this website.
• Profile Data includes your preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Special Category Data includes information about your health, for example whether you have a disability. It also includes information about your race and ethnicity.
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We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

The personal data is needed so that we can provide services to you. If you do not provide the personal data asked for, we may be delayed or prevented from providing those services.

3. How is your personal data collected?

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services, such as a grant;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a survey; 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 our cookie policy 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 is collected from the following parties:
  • analytics providers such as Google based outside the UK;
  • platform services and hosting such as Webflow based outside the US.
• Identity and Contact Data is collected from publicly available sources such as Companies House and social media platforms inside the UK.
• From our third-party partners (see section 4) where you apply for a grant through them and we act as a joint controller to deliver your grant application.

4. How we use your personal data

Legal Basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
  
  

Special Category Data

There are certain circumstances when we process special categories of data which is limited to your race, ethnicity and/or your health.

Where we may ask for, and process, information classed as a special category and we will rely upon your explicit consent to do this.

Health data, for example information on disabilities, is processed so we can make any appropriate reasonable adjustments for you, ensure we communicate with you effectively, and for equal opportunities monitoring purposes. Where we process information on race and ethnicity, we do to ensure equal opportunities monitoring purposes and to source external funding for our grants. In all these instances, we will not use your data for any purpose other than for which it was sought. We have internal policies and controls in place to ensure that special category data is not misused, disclosed or accessed except by our employees in the proper performance of their duties.

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 the various categories of 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.

Direct Marketing

When we receive your grant application and process your application, you will be asked to indicate your preferences for receiving direct marketing communications from SWEF.

Third-Party Marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting Out Of Marketing

You can ask to stop sending you marketing communications at any time contacting us at compliance@swef.uk.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to your grant application, updates to our Terms and Conditions and this Policy and checking that your contact details are correct.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• External third party service providers, for example companies who help us to operate our website.
• Our third party partners who are our community partners. We work with our partners to deliver grant funding and share your feedback (where you have given us your consent) to measure the efficacy of our work. These include, but are not limited to:
  1. The Black South West Network
  2. Young Devon
  3. Gloucestershire Community Foundation
  4. Dorset Community Foundation
  5. Wiltshire Community Foundation
  6. Somerset Community Foundation
  7. Staffordshire Community Foundation
  8. Lincolnshire Community Foundation
  9. South Yorkshire Community Foundation
  10. Hampshire Community Foundation
  11. Cornwall Community Foundation
  12. Heart of Bucks Community Foundation
  13. Forever Manchester
  14. The Community Foundation Northern Ireland
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• 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.

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.

We may share your personal data with our professional advisers, for example our legal advisers, and/or other third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our site terms of use, or to protect the rights, property or safety of our site, our users and others. We will, however, ensure that sharing of your data is kept to a minimum.

We use Google Analytics to collect information as to those who use our website, including IP addresses, unique identifiers, device and software details, mobile phone carrier and geo location data. This helps us to understand the use that is made of our website. Google is prohibited from using our data for any other purposes. Go to www.marketingplatform.google.com/about/analytics/terms/us/ to read the Google Analytics Privacy Policy.

We may be required to disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Third Party Partners - Joint Controllers

Being a joint controller means that we jointly determine the purposes and means of processing the same personal data with another joint controller.

We act in partnership with our community partners to:

• Process grant applications;
• Award funding;
• Obtain your feedback.
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We act as joint controllers in the following circumstances:

1. Where a third party partner receives a grant application for a business grant.
2. Where we receive a grant application directly and the applicant is located in a region where we have a third party partner. We will ask your consent to share your personal data with our third party partner to process your application and award funding.
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In these circumstances we remain responsible for complying with all obligations of controllers under the UK GDPR.

We have agreed our roles for processing your personal data with our third party partners and our responsibilities for complying with the UK GDPR are set out in this privacy notice.

We are not acting as a joint controller where we are processing the same personal data for different purposes.

6. 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.

7. How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may 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.

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.

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

In some circumstances you can ask us to delete your data: see section 8 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.

8. Your Legal Rights

You have a number of 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 "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see opting out of marketing in section 4) for details of how to object to receiving direct marketing communications).
• 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 (see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
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  • 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; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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If you wish to exercise any of the rights set out above, see Contact details in section  9.

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.

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.

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.

9. Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our data protection manager in the following ways:

• Email address: compliance@swef.uk
• Postal address: 
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  SWEF C.I.C.
  C/O Tozers Llp (Ref Jje)
  Broadwalk House, Southernhay West.
  Exeter. United Kingdom
  EX1 1UA
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10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details above.

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

We keep our privacy policy under regular review. This version was last updated on 10th April 2024. Historic versions can be obtained by contacting us.

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, for example a new address or email address.

12. 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