“My Ten Nights” is the trading name of Shamaazi Limited (“we”, “us” or “Shamaazi”). We take the privacy of your information very seriously. This Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be collected in person from you, obtained via our websites or apps, or collected through other means such as by an online form, email, or telephone communication.
This notice applies to the charitable donation and related services we provide (the “Service”) and relates to any personal information provided by our users, customers and contacts (including donors and other users or guests on our sites or apps) whose data we process.
In this notice “you” refers to any individual whose personal data we hold or process. This notice is governed by the EU General Data Protection Regulation and UK GDPR (collectively referred to as the “GDPR”).
Personal data we collect and how we process this data
Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:
Contact information for donors who donate through the Service, as well as any individuals who sign up to our mailing list (or ask or agree to receive information relating to our products and services) and our users generally who may contact us. This information may include names, email addresses, phone numbers, postal addresses, and product or service preferences (“Contact Information”). We process this information when we communicate with you or provide services to you on the basis of the performance of our contract with you, or if we have no ongoing contract with you on the basis of our legitimate interest in providing and operating the Service.
Information relating to any donations made through the Service (“Donation Information”) which may include value of donations, dates and times of donations, the charities or organisations in receipt of donations and records of total donations. We process this information when we process and manage donations on the basis of the performance of our contract with you, or if we have no ongoing contract with you on the basis of our legitimate interest in providing and operating the Service.
Information provided in relation to comments or reviews posted to the Service (“Comment Information”). We process this information on the basis of our legitimate interest in providing the Service and displaying such comments or reviews.
Information provided relating to payment for your donation such as credit or debit card information (“Payment Information”) and please note that Payment Information may be supplied directly to a third party payment processor who will process the data in accordance with their own privacy notices or policies (see below). We process this information when we manage donations or collect or process payments on the basis of the performance of our contract with you in providing the Service.
A record of any correspondence or communication between you and us (“Communication Information”). We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you, or if we have no ongoing contract with you on the basis of our legitimate interest in providing the Service and communicating with our users.
Marketing information we may hold about you in order to provide information about the Service which may include names, email addresses, phone numbers, addresses, and other information regarding your preferences and otherwise (“Marketing Information”). We process this information in order to communicate with you about our products and services on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receive such information.
We will collect the above information from you directly but there may be occasions when we collect information from a third party. If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
This Privacy Notice also applies to personal data provided by our partner charities (which may include the organisation, firm or entity for whom you work) and their staff, and any third party suppliers whose data we process. When we process personal data of this nature we do so on the basis of the performance of our contract with your employer or engaging organisation, or if we have no such ongoing contract on the basis of our legitimate interest in providing and operating the Service.
Data Retention
Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:
Records relating to a contract with us - 7 years from either the end of the contract or the date you last used the Service, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim.
Marketing records - 3 years from the last date on which you have interacted with us.
For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
Cookies and IP Address
Please refer to our Cookies Policy for information regarding our use of cookies. The policy can be viewed here.
Sharing Your Information
We may disclose information to third parties in the following circumstances:
In operating the Service we may provide information to our third party service providers, including payment processors and suppliers who assist with email distribution, IT services and customer services.
Your information may be shared with the charities or organisations to whom you have donated or expressed an interest in through the Service. Subject to satisfactory due diligence, we may agree that charity partners are controllers of your data in common with us, as opposed to processors subject to a separate data processing agreement.
This allows the recipient entity in question to, among other matters, verify and process your donations, claim Gift Aid from HMRC, and (subject to your selected marketing preferences) make contact with you.
Your name will not be provided unless you provide appropriate permissions.
If you consent to being contacted by the recipient charity or organisation you will need to contact that entity directly if you wish to raise any queries or concerns regarding your personal data or to exercise your privacy rights in relation to the data they hold and process about you, including if you wish to revoke your consent to their contacting you and processing your data.
We may disclose information to our group companies for internal operational reasons.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
In order to enforce any terms and conditions or agreements for our services that may apply.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or during the course of third party investment into our business, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
Security
We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage.
Your Privacy Rights
With respect to your personal data, you have the right to:
request that your personal data will not be processed.
ask for a copy of any personal data that we have about you.
request a correction of any errors in or update of the personal data that we have about you.
request that your personal data will not be used to contact you for direct marketing purposes.
request that your personal data will not be used for profiling purposes.
request that your personal data will not be used to contact you at all
request that your personal data be transferred or exported to another organisation, or deleted from our records.
at any time, withdraw any permission you have given us to process your personal data.
All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below. We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection manager.
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
Transferring Your Information Outside Europe
We will not transfer your personal data in a systematic way outside of the European Economic Area or UK (“EEA”) but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
If you are based outside of the EEA or use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services.
We may communicate with individuals or organisations outside of the EEA in providing our services and those communications may include personal information (such as contact information), for example you may be outside of the EEA when we communicate with you.
From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
Contact Us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so by us using the details below:
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting www.ico.org.uk for further assistance.