Privacy Policy

This Privacy Policy (the Policy) was last updated on 1st February, 2019

If we make any changes to this Policy, we will publicise these changes clearly on our website or contact you directly to let you know when there have been any significant changes. Please do revisit this Policy each time you consider giving your personal information to IFAW.

Our Commitment

IFAW is committed to preserving and respecting your privacy and we will always do our best to protect your personal information and keep it safe, whether on this website or by any other means.

One important thing for you to know is that we will not sell or exchange your personal information for marketing purposes.

Please take the time to read this Policy, which explains how we collect and use your information. It is important to us that you understand what information we collect and how we use it. If anything is unclear, please let us know.

If you have any queries or concerns about our Privacy Policy or Cookie Policy please

Email us:
data-compliance@ifaw.org

Write to us:
The International Fund for Animal Welfare
87-90 Albert Embankment
London, SE1 7UD

Call us:
Supporter Development
0207 587 6700

If you have raised a concern about our Privacy Policy or our handling of your personal data, and you are not satisfied with our response, you are entitled to make a complaint to the Information Commissioner’s Office – see https://ico.org.uk/concerns/ for further information.

Who we are

The International Fund for Animal Welfare (IFAW) is an international animal welfare organisation and our mission is to rescue and protect animals around the world.

IFAW operates through three entities in the UK: the International Fund for Animal Welfare (IFAW) (Registered Charity No. 1024806, Company No. 2701278 – referred to as ‘IFAW UK charity’ in this Policy); International Fund for Animal Welfare IFAW In Action (Company No. 1556892); and IFAW Commerce Limited (Company No. 7572366).

This Privacy Policy applies to all IFAW entities in the UK and the US* who are joint controllers of your information under the conditions of the EU General Data Protection Regulation (GDPR). Broadly, ‘controllers’ are individuals or companies that collect personal information about individuals and determine how that information will be used and why, i.e. they have primary ‘control’ over the information they collect. It is possible for two or more individuals or organisations to be joint controllers, i.e. jointly make decisions about what personal information they will collect and use and why. The IFAW entities listed above may each be data controllers of your personal data and may sometimes be joint controllers. They each have different roles, but some activities they undertake overlap and personal information may be shared between them for certain purposes.

For example, the US entity might plan an activity with IFAW UK charity and the two organisations might decide which newsletter we will send and to which supporters as part of that activity.

When we refer to ‘we’, ‘us’ and ‘’IFAW’ in this policy, we are referring to the entities listed above.

IFAW UK charity is the main contact point for managing queries from individuals whose personal information we process and for anyone wishing to exercise any of their rights in relation to their personal information. If you have any queries about the relationship between the IFAW entities above in respect of your personal information then please get in touch.

IFAW’s US entity, International Fund for Animal Welfare, Inc., is a Massachusetts nonprofit corporation registered at 290 Summer St., Yarmouth Port, Massachusetts 02675, US.

What information do we collect, use and store?

We might collect, store and otherwise use the following kinds of personal information about you:

  • Your name and contact information, including your physical address, email address and telephone number (when you provide such information to us);
  • Volunteered information you have provided when contacting or speaking with us or interacting with us via social media;
  • Your financial information when you provide it;
  • The amount and frequency of donations you have made to us;
  • Your content subscription preferences;
  • Web browser and browsing data: browser type, device type, IP address, referral source, the fact that you are visiting our website or clicking on our content, length of website visit, number of page views;
  • Your date of birth and gender;
  • Details of your qualifications and experience;
  • Information about our services which you use/ which we consider may be of interest to you; and/ or
  • Information you choose to share with us.

For more information please see “How we Collect your Personal Information”.

How we collect your personal information

We collect and store information about you when you interact with us in the following ways:

3.1 Supporters
We will collect personal information (for example, your name, address, date of birth, e-mail address and telephone number) provided by you to us directly when you engage with us, for example when you:

  • Make a one-off donation or set up a regular gift (we will also collect bank or credit card details);
  • Give us information on your gift aid eligibility;
  • Subscribe online to receive IFAW e-Alerts;
  • Participate in our online advocacy campaigns;
  • Request information about IFAW, including our programmes and Campaigns;
  • Respond to our mailings, contests or prize-draws;
  • Speak to us on the telephone (we will note anything relevant);
  • Contact IFAW or become involved with us in another way (including via social media);
  • Request information on leaving IFAW in your will, use our Free Will Service or let us know you have left IFAW in your will;
  • Let us know you are fundraising on IFAW’s behalf;
  • Give us feedback or make a complaint;
  • Attend IFAW events; and
  • Complete a London Marathon application form.

Job applicants and volunteers:
We will collect personal information (for example your name, address, date of birth, e-mail address, telephone number, work history) when you apply for a job or register as a volunteer.
For more information click here.

You can give your information to IFAW on other occasions, for example:

Events:
We will collect personal information (for example your name, address, e-mail address), if you sign up to receive information from IFAW when you attend an event (e.g. an Educational Fair), where IFAW is represented;
Fundraising events - when you inform us you are fundraising for IFAW;
Photograph and Video – when you give IFAW permission to use your image in a photograph or video or for which you have copyright.


Who we share your information with

We will not sell your personal information or share it with other charities or organisations for marketing purposes.

However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Notice. We will never give individuals/service providers any rights to use your personal information (or to contact you) except in accordance with our instructions.

Non-exhaustively, those parties may include:

  • Suppliers and sub-contractors for the performance of contracts we enter into with them, for example IT service providers, website hosts and server providers and handling of responses to mailings, including the processing of IFAW donations;
  • Insurers and professional service providers such as accountants and legal services providers;
  • Individuals who we contract to assist us in our activities, such as a consultant campaigners or consultant administrators, etc;
  • Financial companies such as Ingenico, SOFORT and PayPal that collect or process donations on our behalf;
  • Regulatory authorities such as tax authorities;
  • Print production and mailing companies we contract to send out information on our behalf;

Social media companies such as Facebook. We occasionally participate in Facebook’s “Custom Audiences” and “Lookalike Audiences” which enables us to display adverts to our existing or potential supporters via Facebook or to suppress certain IFAW adverts from our existing supporters’ Facebook feeds e.g. an advert directed at signing a petition when you have already signed it. In order to do this we provide supporter names and email addresses to Facebook to enable them to determine if you are a registered account holder with Facebook. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account. Depending on your settings our adverts may then appear when you access Facebook and on your Facebook feed, as well as on other third-party websites and applications. For more information please read the Facebook Business page about Custom Audiences and Facebook’s Data Policy.

  • Organisations that administer IFAW sweepstakes, contests, entries and winners;
  • Companies and individuals instructed to assist during the organisation of an IFAW event;
  • Free will writers when you sign up to receive a Free Wills Information Pack;
  • Telemarketing agencies when we use an agency to telephone supporters on our behalf;
  • Data suppliers such as the Royal Mail Group Ltd.’s National Change of Address database and deceased suppression list;
  • HMRC in order to claim Gift Aid; and
  • Under special circumstances we may need to share or disclose your personal information in order to comply with any legal obligation or where required for the purposes of fraud protection.

We have contracts in place with our service providers which ensure that they:

  • Can only use the personal information for the limited purposes which we have outlined;
  • Delete or return the personal information after a specific time period or at the end of the contract;
  • Take appropriate measures to ensure the security of processing;
  • Ensure that anyone acting on their behalf is subject to a strict duty of confidentiality;
  • Will notify us of any data security breach without delay; and
  • Shall permit a third-party audit on our request.

If we ever were to merge or partner with other organisations your information may be a transferred asset, or in the event that a portion or all of our assets are sold or transferred to a third party, your personal information would likely be a transferred asset.

How your donation is processed

Online donations are securely processed by our PCI (Payment Card Industry) compliant payment service providers. This is the international standard for safe card payment processes. Our systems do not directly collect or store payment card information e.g. the full 16-digit number on the front of the card or the security code on the back. Your payment details are collected in an encrypted form (SSL Protocol). Any credit card details provided to IFAW over the phone are retained only for as long as it takes to securely process your payment, at which point all but the last 4 digits of your card number are redacted from our records.

Offline donations made by cheque, monthly debit or credit card are securely processed either by IFAW or our PCI compliant trusted service providers.

How your information is kept secure

IFAW is committed to keeping any data you provide to us safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information. All IFAW staff and volunteers handling personal information receive comprehensive data protection training. IFAW’s website has security measures in place to protect the loss, misuse and alteration of the information under our control. This includes a firewall and 24-hour monitoring of site activities by our hosting service provider as well as 256-bit SSL encryption protection (where permitted by law) on all transaction oriented operations between you and IFAW via our transaction service provider.

We make no representations about any other websites, and when you access any other website through a link on our website (including social media sites), you understand that it is independent from IFAW and that we have no control over that website or the way your personal information is collected through those websites. Those websites may have their own privacy policies and we encourage you to look at those policies or contact the website operators directly to understand how your personal information is used.

When we enter into agreements with our service providers we ensure that your personal information is handled securely through contractual agreement.

We also do everything we can to protect user-information off-line. IFAW offices are securely locked and protected, our computers are encrypted and secured and any hard copies of personal information are kept locked away outside office hours.

Where your personal information is transferred, processed and stored

Given that we are part of an international organisation, your personal information may be transferred to and stored outside of the European Economic Area (EEA). For example, when we collect your personal information it will be transferred to, processed by and stored with our US entity - International Fund for Animal Welfare, Inc., a Massachusetts nonprofit corporation registered at 290 Summer St., Yarmouth Port, Massachusetts 02675, USA. It may also be transferred, processed and stored by Cloud service providers and suppliers both within and outside the European Economic Area (“EEA”). The data may also be processed by staff of other IFAW country offices within the EEA as well as entities operating outside the EEA (Australia, Canada and South Africa). We are aware that legal protection for personal information in countries outside the EEA may not be equivalent to the level of protection within the EEA. Therefore, in order to further safeguard your personal information and ensure you have the same level of protection, IFAW UK holds an EU Standard Contractual Clause agreement with IFAW United States.

When we enter into agreements with our service providers we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses or ensuring they are signed up to the US Privacy Shield) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Notice.

If you have any questions about the transfer of your personal information, please contact us.

Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.

The length of time your personal information is stored

We will keep your personal information in accordance with applicable regulations. We make every effort to destroy, archive, anonymise or minimise personal information that we hold when it is no longer needed for the purposes for which it was collected.

If you are an active IFAW supporter (by donating or communicating with IFAW within the last 5 years), we will keep a record of your personal information and continue to keep a record of donations you have made since you first donated to IFAW unless you ask us not to. We believe it is important to both you and IFAW that our records accurately reflect your support, and this also helps make future engagement with you as personal as possible.

If you are no longer an active IFAW supporter (after 5 years without a donation or communication from you), we will retain only the following personal information to meet financial and legal requirements: your name and address details; the fact that you have left IFAW in your will (where you have informed us of this); and details of all your current and past donations for a maximum of 10 years. We will not process your personal information for fundraising purposes.

After 10 years since you last donated to IFAW, we will continue to retain your name and address details to keep on record the fact that you have left IFAW in your will (where you have informed us of this). We will also retain a brief summary of your donation history (the date of your first and last donation and the total value of your donations), to support the administration of any legacy you have pledged or may choose to pledge in the future.

Children

If you are under the age of 16 and do not have explicit permission from your parent, guardian or teacher please DO NOT USE IFAW’s website and social media sites.

We do not purposefully or knowingly collect personal information from children under the age of 16 without IFAW receiving consent from a parent or guardian or teacher. With permission, we may collect information when a child participates in an IFAW Education art or writing contest, to collect feedback on our education materials, to attend special events or when a legal waiver is signed, for example, for permission to use photographic or video footage. With permission, when your child has fundraised for IFAW, we will keep a record of their donation but will never knowingly send them marketing materials.

If you are a parent or guardian of a child under 16 years of age, and believe that he or she disclosed information to us, please contact the Supporter Development Team, IFAW, 87-90 Albert Embankment, London, SE1 7UD or email info-uk@ifaw.org. If we learn that we have collected or received personal information of persons who are under 16 years of age without verification of parental consent, we will exercise commercially reasonable efforts to delete this information.

Free will service

When you sign up to receive a Free Wills Information Pack, including on the “Free Will Service” page of our website, your name and address will be passed to the National Free Wills Network so that they can send you the requested information.

There is no obligation to leave a gift in your Will to IFAW as part of the Free Will Service. Your Will remains confidential and we will not receive a copy, but the National Free Wills Network will let us know if you have left a gift to us so that we can inform our legacy team and send you a thank you letter.

If you would like further information on how your details will be used when you use the Free Will Service, please contact IFAW’s Legacy team by calling 0207 587 6706 or sending an email to legaciesuk@ifaw.org.

Legal basis for processing your data

When dealing with your personal information we will at all times comply with Regulation (EU) 2016/679 (GDPR) to the extent required by law and any other applicable legislation. The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the following grounds to be most relevant:

Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you fundraising material by email, and we may ask for your explicit consent to collect special categories of your personal information).

Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).

Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, if you apply to work for/ volunteer with us).

Where there is a legitimate interest in us doing so.

The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).

In broad terms, our “legitimate interests” means the interests of running IFAW and pursuing our aims and ideals; for example, pursuing a world where animals are respected and protected.

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

Specific examples of when we might rely on the above bases include:

  • Postal mail - we rely on our legitimate charitable interest for the purposes of raising funds and raising interest in our mission by sending postal mail. We may at times ask for and rely on your consent to send you postal mail.

  • Email - to contact you by email for fundraising or advocacy purposes we will always require your consent and will regularly confirm with you (and at least every two years) that we still have your consent. You will be given the opportunity to withdraw your consent on every fundraising email IFAW sends you.

  • Telephone – if you have given your consent, we will use a phone number you have provided or a phone number available from public sources (e.g. telephone directory) in order to call you for fundraising, stewardship (e.g. to invite you to events or update you about our work with animals and how you can help) or administrative purposes (e.g. confirmation of donation). We may at times rely on our legitimate charitable interest to contact you by telephone. We will never call you if you have asked us not to, or call without your consent for marketing purposes, if you are registered with the Telephone Preference Service. At the start of each fundraising call, we will ask for your permission to continue the conversation. You can ask us not to call you at any time. We will only call you for fundraising or stewardship purposes if you have positively engaged with IFAW in the last 18 months. If you have not positively engaged with IFAW in 18 months, we will only call you for administrative purposes unless you have asked us not to. Administrative purposes – we rely on our legitimate charitable interests to contact you for administrative purposes e.g. to clarify a request you have made or to acknowledge your donation.

  • Administrative purposes – we rely on our legitimate charitable interests to contact you for administrative purposes e.g. to clarify a request you have made or to acknowledge your donation.

  • Research purposes – all our research supports IFAW’s mission and depending on the type of research we will rely on your consent (e.g. in a voluntary survey) or on our legitimate charitable purposes (e.g. when we investigate wildlife issues).

  • Education - we rely on our legitimate charitable interests to send information to teachers and educators by mail and will always get consent for emails.

  • Job applications – we rely on our legitimate charitable interests in order to process your application.

  • Donations - we have a financial and legal obligation to hold your personal information for 10 years and will rely on our legitimate interests to process personal information to fulfill a donation you make to us.

We may also hold your information where necessary for the performance of a contract with you.

If we are relying on your consent to do something with your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for campaigns or fundraising purposes or to unsubscribe from our email list at any time Please note we may need to keep some of your information for legal purposes.

You also have other rights in relation to the way we use your information – for example, if we are relying on legitimate interests, you can object to us using your information on this basis. Please see ‘your rights’ for further information.

Your rights

You have various rights in respect of the personal information we hold about you. IFAW shall provide information on action taken when you make a request regarding your rights without undue delay and in any event within one month.

Your rights are as follows:

  • Right to Access – you have a right to request confirmation of what personal information we hold about you and to request a copy of that personal information. This includes the personal information we use, why we use it, who we share it with and where possible how long we intend to keep it. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.

  • Right to Rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate / up to date.

  • Right of erasure / right to be forgotten – you can ask IFAW to delete your personal information where it is no longer necessary for us to use it or where you have withdrawn your consent or where we have no lawful purposes for keeping it. We may need to retain your personal information or some of your personal information for financial regulatory or legal requirements

  • Right to restrict processing – you have the right to ask for processing of your personal information to be restricted in some circumstances such as if there is disagreement about its accuracy or legitimate usage – for example, you might tell us that you think we hold some information about you that is inaccurate. Whilst we take steps to check this and ensure it is accurate, you have the right to ask us not to use your personal information

  • Right to Portability – to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format

  • Right to object to processing – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests ground, (ii) using your personal information for direct marketing (this can include postal marketing, email marketing, telephone marketing, text message marketing, any profiling activity and online behavioural advertising) or (iii) using your information for statistical purposes

  • Rights related to automated decision-making – you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation; (ii) is authorised by EU or Member State law to which IFAW is subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information requested by you.

Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details below.

Contact us

If we hold your personal information please contact us if you:

  • no longer want to receive post from IFAW
  • no longer want to receive emails from IFAW – (please note instructions for unsubscribing from e-mails are included in each e-mail alert we send)
  • would like IFAW to stop processing any or all of your data in any particular way
  • have a change in your contact details
  • want to find out about the information that we hold on you
  • want to exercise any of your rights
  • wish to make a complaint about the way in which your personal data is handled by IFAW

You can let us know by:

Supporter Development
International Fund for Animal Welfare
87-90 Albert Embankment
London SE1 7UD

  • Calling the Donor Relations team on: 0207 587 6700

To the extent that your query relates to IFAW US, IFAW Germany Company Number HRB35636, Max-Brauer-Allee 62-64, 22765 Hamburg acts as its EU Representative. Because IFAW US is a US organisation, EU data protection law requires it to appoint a ‘representative’ in a country in the EU, as a point of contact for EU-based data privacy questions and queries. IFAW Germany can be contacted by telephone at +49-40-866 500-0 or email at info-de@ifaw.org. However, in the first instance please contact IFAW UK using the details set out above. IFAW UK will pass your query on to IFAW Germany if appropriate.

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