Your privacy is important to us. The information below sets out how we collect, use and protect any personal data that you give to us.

It also sets out details about your rights in relation to the personal data that we hold about you and how to contact us if you have any questions or would like to change the way in which we communicate with you.

We may change this Privacy Notice from time to time in order to remain compliant with changes to regulation. Should this be the case and we need to make any significant changes in the way we treat your personal information, we will make this clear on The Donkey Sanctuary website or by contacting you directly. For further information please see the Information Commissioner’s guidance.

Who we are

We are a UK registered charity (264818) and are registered as a data controller with the Information Commissioner’s Office. The Donkey Sanctuary’s vision is a world where donkeys and mules live free from suffering and their contribution to humanity is fully valued.

Whenever we collect personal data, we will always have clear marketing preference questions and information on how you can choose if and when we contact you. The Donkey Sanctuary and its charitable and trading subsidiaries will never sell your data. If you don’t want to hear from us, that’s fine. You can update your communication preferences by either writing to the Supporter Services team, The Donkey Sanctuary, Sidmouth, EX10 0NU or calling our team on 01395 578222.

If you have any questions or concerns about how we handle your personal data you can contact The Donkey Sanctuary by either writing to The Data Protection Officer, at the above address or by emailing [email protected]

We also have a subsidiary company Donkey World Limited (company number 04452098) whose registered office is at the address below. Donkey World Limited runs our shop and undertakes other trading activities for The Donkey Sanctuary. Donkey World Limited processes personal data on behalf of The Donkey Sanctuary. All profits are remitted to The Donkey Sanctuary. Our registered office for both is: The Donkey Sanctuary, Sidmouth, EX10 0NU.

The ways we collect personal data

When you share personal data with us directly

We collect personal data about you if you fill in forms on our website or correspond with us by phone or email, enter competitions and sign up to petitions.

Personal data that we process could include details such as your name, postal address, phone number, email address, date of birth, IP address or banking details. We collect this for a variety of reasons, such as responding to your enquiry, providing a service or processing your donation.

If you give us personal information about a third party, for example, when you’re buying a donkey adoption as a gift for a friend – we’ll also let them know how we plan to use their data (to send them their newsletters) and we’ll give them the option of not receiving communications in the future.

When you use our website

Like most websites, we use ‘cookies’ to help us make our website – and the way you use it – as relevant and interesting to you as possible. Cookies mean that a website will remember that you have visited our site. You can find out more details on how we use cookies.

Our website contains forms that you can complete. We only ask for the information we need in order to provide you with the services, products or information you have asked for. Forms submitted online are automatically turned into an email and sent directly to a member of staff. If you would prefer, you can print out and post us the form.

Profiling to help us understand your preferences

We may profile visitors to our website in terms of preferences, interests and practical support to help us know what information you would be most interested in receiving.

In partnership with certain agencies Google Analytics and Google Marketing Platform (DoubleClick) help us to understand how visitors are using and engaging with our website and apps. This allows us to make improvements to our web services and your online experience.

For more information about Google’s data privacy and security in regards to Google Analytics, please read Google’s policies and data privacy information page.

In addition to reporting website usage statistics, we use Google Analytics in conjunction with additional advertising cookies. We use these cookies to select advertising based on what is relevant to you, to measure interactions with the ads we display and to improve reporting on campaign performance.

Publicly available information

On occasion, we may use publicly available information to gain a better understanding of our supporters to improve our fundraising methods, products and services. This may include information found in places such as Companies House and information that has been published in articles or newspapers.

When we receive information from other sources, we rely on those sources having the appropriate provisions in place telling you how they collect data and who they may share it with. We carefully check our sources to ensure that we only receive your information when it is lawful for us to do so.

When you support us via a third party

In some cases, your information may be shared with us by another organisation, for example fundraising sites like Just Giving. These independent third parties will only do so when you have indicated that you wish to support The Donkey Sanctuary and have given your consent.

When you have given permission to another organisation to share your information

You may have given permission for a company or other organisation to share your data with third parties. This could be when you buy a product, register for an online competition, complete a survey or sign up with a comparison site.

When you have given permission using social media

Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those accounts or services.

When your image is captured by CCTV, filming or photography on site

Your image may be captured while you are on our premises. We have CCTV in operation across our sites and retain footage for a limited time unless it is connected to an ongoing investigation. We film and take photographs at events held at our premises. Your image may be captured in this way unless you notify a member of staff on the day of your visit to confirm you do not wish to be captured on camera. If we choose to feature specific individuals (adults or children) we will ask your permission prior to using an image. We will request your written consent to use your images for marketing purposes.

How we use your personal information

We will collect, store and use the personal data you provide to us in order to carry out the activities relevant to the provision of our services to you.

We may use the personal information held about you in the following ways:

- To provide you with information, which you have requested, about ways to support The Donkey Sanctuary, our services and campaigns

- To provide you with the information, products and services that you request from us, such as rehoming a donkey

- To be used as part of our efforts to prevent or detect fraud or abuses of our website

- To analyse and report on the number and nature of contacts with the organisation

- To carry out research on the demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them and to enable us to improve our services. This research may be carried out internally by our employees or we may ask another company to do this work for us

- To provide you, or permit third parties to which you have consented, to send you information that we think may be of interest to you

Lawful basis for processing

We must have a legal basis for processing your personal data. We consider that we have a legal basis where:

a) You have given us consent to do so for the specific purposes which we have told you about

b) It is necessary for us to do so to enable us to provide you with the services that you have requested from us – for example, billing you or contacting you about the donations

c) To provide you with information that we think may be of interest to you if you have agreed to receive it, or the law otherwise permits or requires it.

d) Where we need to comply with a legal obligation.

Where we process your personal data on the basis of our legitimate interests, these are our (or our third party’s) interests in providing our services to you in an efficient and secure manner.

Marketing communications

We’d like to ensure that you know about the progress we are making and to ask for donations or other support (such as adding your voice to a campaign or giving your time, for example). Occasionally, we may include information from partner organisations or organisations who support us in these communications – for example, those working with us to improve the welfare of donkeys.

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

If you prefer not to receive any marketing communications from us, you can change your preferences and unsubscribe at any time by either writing to The Supporter Services team, The Donkey Sanctuary, Sidmouth, EX10 0NU or calling our team on 01395 578222 or unsubscribe using the unsubscribe button located at the end of the email. If you choose not to receive this information we will be unable to keep you informed of new products, services and promotions that may interest you.

Profiling to enhance user experience

We may make use of additional information, including information about where you live, when it is available from external sources to help us create a profile of your interests and preferences. This enables us to ensure communications are relevant and timely and provide an enhanced experience for our supporters. It also helps us understand the background of our supporters so that we can make appropriate requests to those who may consider making a donation again, enabling us to raise funds sooner, more cost effectively and proportionately than we otherwise would.

We may use third party suppliers to undertake these activities on our behalf and share your information with them to the extent required. Such information is compiled (either by us or our suppliers) using publicly available data e.g. addresses, information available from public registers, such as listed Directorships, information from the electoral roll and media coverage.

We may interpret your personal data and predict how likely you are to be interested in or responsive to a particular campaign or fundraising message. Where we have identified that you may have the capacity and/or affinity to support the Donkey Sanctuary, we may collect additional information about you and combine, analyse and compile that information into an assessment of you in order to assist us in engaging with you in a more personalised way. We hope this will then enhance your user experience.

Types of personal data we gather

We typically look at and combine information published in the media but may obtain personal data other commonly used publicly available sources including company resources, the Electoral Register and any data you choose to make public on LinkedIn such as your professional memberships and networks. We may also use any publicly available data that you share on social media. We may use additional information such as geographical information for measures of affluence where available.

In order to do this efficiently, we may use trusted third party specialist companies that collate and analyse information from public registers alongside statistical social-economic data to automate some of this work. This helps us to understand more about your interests and level of potential engagement or donation. We will not send you a marketing communication by email or automated telephone call unless you have already provided us with consent to receive those communications. You may opt of your data being combined and analysed for marketing purposes and opt out of receiving those communications at any time by contacting our Supporter Services team.

Who will have access to your information

We make sure that there are appropriate controls in place to protect your personal details in accordance with current data protection legislation. We undertake regular reviews of those who have access to information that we hold to ensure that your information is only accessible by appropriately trained Donkey Sanctuary staff, volunteers and contractors.

We may share your personal data with third-party service providers who assist us with administering the provision of our services to you including:

- With business partners, suppliers and sub-contractors

- To HMRC in relation to Gift Aid when your consent has been obtained

- With analytics and search engine providers that assist us in the improvement and optimisation of our website

- With our regulator, the Charity Commission, and the Fundraising Regulator in order to comply with our regulatory obligations and to help resolve complaints or other issues

- With agents we engage to perform functions on our behalf including fulfilling order deliveries, sending customer communications, analysing data, providing marketing assistance, processing payments and providing customer service. They have access to personal information needed to perform their functions but may not use it for other purposes. Where we use external companies to collect or process personal data on our behalf as described above, we carry out comprehensive checks before we work with them.

We may want to use some of the information provided, including gender or age or to publicise The Donkey Sanctuary’s work. We will only make this information publicly available if we have your explicit and informed consent (or your parent or guardian if you are under 18) and we will always seek such consent prior to using your information publicly.

How we look after your data

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.

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.

Transfers outside the European Economic Area

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your information, you agree to such transfer, storing or processing by staff operating outside the EEA who work for us, or one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

How long do we keep your personal information

We will keep your personal data for no longer than necessary for the purposes we have set out above. We will retain your information for as long as needed in order to provide the relevant goods or services to you or perform any contract we have with you and for period afterwards in order to deal with any queries or maintain your communications preferences.

Third party providers

Any third parties that we engage will keep your data stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third-party providers, we will make sure that they securely delete or return your personal data to us.

Your rights

You have a number of rights in relation to your personal data. There are circumstances in which your rights may not apply. You have the right to request that we:

- Provide you with a copy of the information we hold about you (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 the 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.

For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us using the details provided below.

In most circumstances a fee is not charged when we provide you with your personal data. A reasonable fee may be charged to cover administrative costs if your request is, for example, excessive or repetitive.

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.

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.

If you have any questions or concerns about how we handle your personal data you can contact the Donkey Sanctuary by either writing to The Data Protection Officer, The Donkey Sanctuary, Sidmouth, EX10 0NU or email [email protected]

(Revised: 16 Aug 2019 16:45)