1. Introduction

Welcome to WE.org, the home of Free The Children (UK) and WE Education Limited.

To start, we would like to define the terms we use in this Policy, so you have any easy reference:

  • App means our mobile/desktop applications

  • Platform means the Site and the App together

  • Policy means this Privacy Policy

  • Site means WE.org

  • Services means the services provided when you browse, use or register on the Platform, as well as any other service that you request from ys

  • We, WE or WE Charity is a brand that represents the data controllers, Free The Children (UK) (a charity registered under the Register of Charities under registration number 1138645) and WE Education Limited (a company registered in England under registration number 08526524) located at 14 Bowden Street, London, SE11 4DS, UK.

  • You and Your means you, the person using the Platform

This Policy sets out the ways in which WE collect and use your information when you browse, use or register for our Platforms, use or register for other Services, as well as contact us or otherwise interact with us.

We may update this Policy from time to time so please remember to check back from time to time to view the most current version of this Policy. Where we have made any changes to this Policy, we will make this clear on our website or contact you about any important changes. This Policy was last amended on the date shown at the end of the Policy. By continuing to use the Platform, you acknowledge that you have read and understood this Policy (as well as reviewed and understood any updates to it).

2. What is personal information?

Personal information is any information that can be used to identify you as an individual, including your name, age, date of birth, personal telephone number, address, credit card details, and email address. It could also include information about the device you use to access the Platforms, information about how you use the Platform, or information we observe derive or infer.

3. Special note to visitors under 13 and 18

If you use our Platforms or Services, you acknowledge that the collection, use, disclosure and management of your personal information will be carried out in accordance with this Policy.

If you are under the age of 18 you must seek parental or guardian (“Your Adult”) permission to use our Platforms or Services before submitting any personal information to WE Charity. You should show this policy to Your Adult and discuss it with them. We reserve the right to refuse access to any of our Platforms or Services in the event such permission is not obtained and to verify consent in certain circumstances including in processing volunteer or scholarship applications or before awarding prizes to competition entrants.

If you are under the age of 13, please read our Notice to Children Under 13 featured on the bottom footer of the Site and make sure that Your Adult provides the necessary permission before you consent to provide any personal information. If they don’t give permission, please don’t give us any personal information. Please also disable cookies in your browser and use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics (Your Adult can help if you don’t know how).

4. How does WE Charity collect my personal information?

Personal information that you provide to us We collect personal information from you through your interaction with our Platforms and Services and your correspondence with us or at our events. This may occur when you participate in, or sign up to, any of our Platforms or Services, such as competitions, mailing lists, registration to attend our events, registrations for an account, make a donation, or apply for a scholarship.

We may also collect information about you when you interact with us directly (for example, when you contact us to ask a question about us and our activities, attend our events, apply for a job or a volunteering opportunity with us, make a donation to us, or otherwise provide us with your personal information by, for example, visiting our website, calling us, interacting with us via social media, getting in touch through the post, or in person.

If you give us information on behalf of someone else, you confirm that the other person has appointed you to do so on his/her behalf and that: (a) they have given their consent for their details to be passed on by you; and (b) you will show this Policy to them.

The information you provide to us will vary depending on the Platform or Service you engage with but may include name, address, phone number, email address, user name, password, age, gender, date of birth, parents’ names and phone numbers, competition answers, your scholarship application and comments, photos, videos or other content you post as a Registered user (see section Visitor Profile Information below). We may also ask for additional information depending on the nature of the service provided. But in all cases, we will comply with our obligations to inform you of how your information will be used, protected and distributed.

We will not normally collect any sensitive personal information from you, and in any event, will request your express consent before doing so.

When you are making a donation via our Platforms you may be pushed towards a third party donation processing site where they will collect personal information (like your name, billing address and information) to execute the requested transaction but it will not be stored on the applicable Platform if you are a visitor user. If you are a Registered user, this information may be stored as part of your profile so that you may make donations in future.

Visitor Profile Information. You are not required to register as a visitor, register your WE Day bracelet, or take the WE Pledge (“Registering”) in order to access the Platforms. Registering may, however, allow you to be registered as a user and access additional functions on the Platforms. If you make a donation without completing a visitor profile, information such as your billing, contact information and preferences will still be collected in order to execute the requested transaction but will not be stored on the Platforms in a visitor’s profile.

Personal information that we collect about you We may collect visual, audio, and sound information about you during our events and activities.

Certain other personal information may be collected on the Platforms without you actively providing the information by using various technologies, as described below:

  • Server Logs. We may collect certain information about the ways in which you use the Platforms, including information about your IP address, geographical information, type of operating system, device information, browser type, referral source, the time you spent on the Platforms and which pages you visited. This helps us improve our Platform. We track IP addresses for: (i) troubleshooting issues; (ii) voting events, to confirm people are not voting for an individual more than once; and (iii) for all people who are filling out online forms, for the purpose of spam filtering. This information may be collected by a third party analytics provider on our behalf and/or may be collected by using cookies (please see below for more information about cookies).

  • Demographic and Interest Reporting. We have implemented Google Analytics features based on Display Advertising (Google Analytics Demographics and Interest Reporting) that allows for the collection of aggregated user data; this includes aggregated gender, age, and interest behaviour data. We will use the data provided by Google Analytics Demographics and Interest Reporting to develop the site and content around our users’ interests. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings. In addition, you can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. https://tools.google.com/dlpage/gaoptout

  • Cookies. Cookies are small pieces of data, usually of letters and numbers, that are downloaded onto, and stored on, your computer, mobile phone or other device. WE Charity may use cookies to provide, monitor and analyse how Services, and Platform are used. Among other things, we use cookies to make the Platforms easier to use, enable features and store information about you and your use of the Platforms as well as to deliver, understand and improve advertising. If you want to learn more about what cookies are, or how to control or delete them, you can visit http://www.aboutcookies.org for detailed guidance.

Cookies can always be disabled by the browser you are using, but some functions of the Platforms may not work if cookies are not enabled. Refer to your browser or device’s help material to learn what controls you can use to remove or block cookies or block or remove other data stored on your computer or device (such as by using the various settings in your browser). However, please note that if you do this, it may affect your ability to use the Platforms or other websites and applications.

You can review the cookies used on our Platforms and the purposes for which these cookies are used in the table below.

Types of Cookies:

1. STYXKEY-country
  • Cookie name: STYXKEY-country
  • What it does: From Pantheon, a cookie to store the User’s 2 character country code for GEO Targetting
  • Resource: https://pantheon.io/docs/cookies/
  • Expiry: 30 min
2. __cfduid
  • Cookie name: __cfduid
  • What it does: The __cfduid cookie is used to override any security restrictions based on the IP address the visitor is coming from. For example, if the visitor is in a coffee shop where there are a bunch of infected machines, but the visitor’s machine is known trusted, then the cookie can override the security setting. It does not correspond to any userid in the web application, nor does the cookie store any personally identifiable information. Note: This cookie is strictly necessary for site security operations and can’t be turned off. To enable screen reader support, press shortcut ⌘+Option+Z. To learn about keyboard shortcuts, press shortcut ⌘slash.
  • Resource: https://support.cloudflare.com/hc/en-us/articles/200170156-What-does-the-Cloudflare-cfduid-cookie-do-
  • Expiry: 1 year
3. _ga
4. _gat
5. _gat_SpuTracker
6. visitor_id72242
  • Cookie name: visitor_id72242
  • What it does: The visitor cookie includes the name “visitor_id” plus the unique identifier for Pardot. Pardot is a marketing automation platform and we use it to gather information about visitors on our website. If a visitors completes a form on our website, for example registering for an event, then their Personal information is stored in Pardot/Salesforce This cookie is set by Pardots tracking code. To enable screen reader support, press shortcut ⌘+Option+Z. To learn about keyboard shortcuts, press shortcut ⌘slash.
  • Resource: http://www.qubeglobal.ca/cookies/
  • Expiry: 10 years
7. we-schools-auth
  • Cookie name: we-schools-auth
  • What it does: This cookie is used only when a user wants to access the WE Schools Hub. It is used to keep a user authenticated in the hub, and helps to provide customised experiences based on the preferences such as location and subscriptions set by a user.
  • Resource: No resource available
  • Expiry: 1 year
8. _scid and _sctr
  • Cookie name: _scid and _sctr
  • What it does: Sentry provides real-time error tracking for web apps, mobile apps and games, which gives developers the insight needed to reproduce and fix crashes.
  • Resource: https://sentry.io/privacy/
  • Expiry: 90 days

Information that we receive from third parties We may also receive and collect personal information about you from third parties. For example, this could be if you make a payment or provide a donation through a third party, or if you register with our Platforms or Services via a third party social media platform, we will receive certain information from such third parties for the purposes of your Registration with WE Charity.

5. Use and disclosure of personal information

Personal information collected by WE Charity will only be used or disclosed for purposes described in this Policy or for other purposes permitted by law. Before your personal information will be used or disclosed for a new purpose, we will ask you for your consent, unless use or disclosure without your consent in the circumstances is otherwise permitted or required by law, regulation or court order. We may use your personal information to:

  • provide you with access to the Platforms and to provide you with our Services (including allowing you to register for, and access the Platforms via, a Visitor Profile);
  • customise the Platforms and Services to your preferences, to improve the content of our Platforms and Services, and to research Platforms’ usage patterns;
  • process donations and other payments, (to claim Gift Aid on your donations) and verify any financial transactions;
  • to perform any contracts we have with you (e.g. if you signed up to attend one of our programmes or events);
  • if you have agreed to receive them, to send you marketing communications about WE Charity content, products, events and promotions that you might be interested in (see section 6 "Marketing" below for further information);
  • if you are under 18, to contact your parents if we need to verify any of the information you have provided to us or, if you are a parent, to contact you in order to verify any information your child may have provided to us;
  • enforce or apply the Terms of Use of the Platforms, to the extent that your personal information is required in order to determine whether the Terms of Use have been violated and to, if applicable, enforce the Terms of Use;
  • provide, administer and communicate with you about our Services, events and promotions (e.g. to enable you to log in to your account, register for events and enter competitions, use your WE Day Bracelet at WE Day);
  • provide your information to our supporters and other third parties where you have explicitly requested us to do so (e.g. by using your WE Day Bracelet at WE Day to request information or services from these third parties);
  • contact you about your Registration, comments you have made on the Platforms, including any requests for information from us;
  • where you work or volunteer with us, to administer the arrangement (including the recruitment process);
  • consider your application to attend one of our events as a Volunteer, Teacher or Honoured Guest or your application for a scholarship and to keep a record of your relationship with us;
  • to manage our relationship with you which may include letting you know about changes to this Policy;
  • keep our Platform, services and operations secure and safe;
  • comply with court orders and to exercise or defend our legal rights, or to protect WE Charity, our staff, our Platform, or others’ rights or property;
  • conduct internal operations (data analysis, troubleshooting, testing and service improvements);
  • measure or understand the effectiveness of the content we provide on our Platform or otherwise; and

  • comply with our legal, contractual, and regulatory obligations.

Legal basis for using your information. We will use your personal information in the following ways:

  • when you have given us your consent;
  • when it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
  • when it is necessary for our legitimate interests (and they do not override your interests); or
  • when we need to comply with a legal or regulatory obligation.

Disclosure of your information. WE will not sell or rent your personal information to anyone. WE may disclose your personal information to our related organisations, including WE Charity organisations in Canada and the United States (subject to the below section that explains how we transfer your information) who agree to follow this Policy, for the purpose of providing you with access to the Platforms and/or Services and/or to otherwise provide you with the information, products or services you have requested from us, solely in accordance with the terms of this Policy.

We may also disclose personally identifiable information to certain other third parties, including:

  • to service providers and third parties that we work with to support our organisation (e.g. technical support or third party services administering our marketing and credit card system and the WE Day Bracelet ticketing system or third party hosting providers) in which case we will require them to process your personal information in accordance with this Policy;
  • social media providers that you have opted to share any applicable Platform account activity or information with (if you share posts to your social media channels, you acknowledge that such information will be made available to users of the applicable social media platform);
  • any other third parties where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees;
  • and/or any prospective organisation that we consent to take control of WE and/or any charity we merge with;

  • other third parties (including, for example, regulators, government bodies, law enforcement agencies, and our legal and other professional advisors) where permitted or required by law, court orders, or government regulations.

Transfer of your information. We are located in the UK. However, the personal information that we collect from you will be stored on our servers at our offices in Canada and United States and those of our third party processors in the USA. As such, personal information that we collect and hold about you will be transferred outside the European Economic Area (“EEA”) and may be processed by staff operating outside the EEA. We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected. When we transfer your personal information to a country other than that in which you initially provided the information, we will ensure that your information is adequately protected and processed in accordance with this Policy and data protection laws applicable in the UK. Among others, we rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses” and the EU-US “Privacy Shield”) to ensure your information is subject to adequate safeguards in the recipient country.

6. Marketing

If you have consented to receive marketing communications from us, you may occasionally receive emails from WE. We hope you will find these emails interesting and informative. Of course, if you would rather not receive this information, you can unsubscribe by following the opt-out instructions contained in any emails that you receive from us. If you opt out of receiving our updates, we may still use your personal data for our other legitimate interests.

7. Accessing your personal information

Subject to certain legal conditions, you have certain rights in respect of the personal information that we hold about you, including:

  • Information: You have the right to be informed of the ways we use your information, as we seek to do in this Policy;
  • Access: You have the right to request, free of charge, access to a copy of the personal information that we hold about you;
  • Rectification: You can ask us to change, correct, or complete any inaccurate, incomplete, or out-of-date personal information that we hold about you;
  • Consent: If you have given us your consent to use your personal information (for example, for marketing purposes), you can withdraw your consent at any time;
  • Objection: You can object to our processing of your personal information 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. You can also object to our use of your personal information for direct marketing purposes;
  • Portability: In certain circumstances, you can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form;
  • Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it; and
  • Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.

Exercising your rights. You can exercise the rights set out above by writing to us at the details set out at the end of this Policy. You will not have to pay a fee to exercise the above rights, however, we reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your information.

Please note that we will likely ask you to prove your identity, just to make sure there is no unauthorised access. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will try to respond to all legitimate requests within one month. Sometimes it may take us longer if your request is complex or you have made several requests. In this case, we will notify you and keep you updated. Please also be aware that not all of those rights are absolute and there may be circumstances in which we will not fully comply with your request because of a specified legal ground or exemption.

Right to lodge a complaint. 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 (www.ico.org.uk), as well as the relevant authority in your country of work or residence) if you do not believe that we have handled your request in an appropriate manner. We would appreciate the opportunity to deal with your concerns before you complain to the ICO – you can contact us using our contact details set out at the end of this Policy.

8. General terms

How long do we keep your personal information for? The short answer – we keep your personal information for as long as necessary to deliver the Platform or Service you request. How long we keep the information absolutely depends on the type of information we are holding and the purpose we collected it. Legal obligations will also inform how long we will hold the information.

Security and Data Retention. We take measures to protect any personal information you supply to us. When you provide personal information through the Platforms, we protect your personal information by encrypting the personal information that is transmitted between you and the Platforms. We will employ security measures to protect personal information in our care from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage appropriate to the level of sensitivity of the information. Please note though that data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. As noted above, we will retain your personal information only for the time it is required for the purposes for which it was collected or as required or permitted by law.

Links to Other Websites. The Platforms and our Services may contain links to other websites or enable you to connect with your own social media accounts. Clicking on those links may allow other people to collect or share data about you. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the content or privacy practices of other websites or services. We strongly encourage all visitors to the Platforms to review the privacy statements and policies of all external websites or services.

9. Contact us

Please contact us by email at [email protected] or in writing to WE Charity (14 Bowden Street, London, SE11 4DS), with any questions or concerns you have about this Policy or about WE Charity’s handling of your personal information. We will investigate and respond to your concerns promptly.

Last Updated: 1 October 2019

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