Privacy policy

1. Purpose

1.1 Unlimit Health (formerly known as “SCI Foundation” or “SCIF”) is a registered UK charity (registered company number 11775313 and registered charity number 1182166) with registered office address at Edinburgh House, 170 Kennington Lane, London, SE11 5DP. Unlimit Health is committed to protecting the privacy and security of your personal information.

1.2 This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the applicable data protection legislation (including the Data Protection Act 2018 and the General Data Protection Regulations, referred to as the “GDPR”).

1.3 Unlimit Health is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

1.4 This notice applies to members of the public who donate to Unlimit Health. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

1.5 It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2. Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. used lawfully, fairly and in a transparent way;

2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

3. relevant to the purposes we have told you about and limited only to those purposes;

4. accurate and kept up to date;

5. kept only as long as necessary for the purposes we have told you about; and

6. kept securely.

3. The kind of information we hold about you

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 There are “special categories” of more sensitive personal data which require a higher level of protection.

3.3 We may collect, store, and use the following categories of personal information about you:

Contact and communications information, such as:

• your contact details;

• your communication preferences;

• records of communications and interactions we have had with you.

Biographical information, such as:

• your name, gender, title, nationality and date of birth;

• your family and partner/spousal details;

• your professional activities and employment, including work contact details;

• information you have publicly shared on social media including your image.

Financial information, such as:

• your donation history, including gift amount, purpose, date, method of payment, cheque numbers or other payment references;

• your bank account number, name and sort code (used for processing Direct Debits);

• tax status and Gift Aid declaration information;

• details of financial transactions e.g. event tickets purchased;

• our assessment of your ability and willingness to make donations, including considerations of income;

• donations to other organisations.

Technical data, such as:

• internet protocol (IP) address;

• your login data;

• browser type and version;

• time zone setting and location;

• browser plug-in types and versions;

• operating system and platform and other technology on the devices you use to access this website.

Usage data, such as the information on how you use our website.

3.4 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregate Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

3.5 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences in relation to our visitors.

3.6 Please note that we do not collect or store any credit/debit card details in our database if you have used these in transactions with Unlimit Health.

3.7 Research, profiling and ‘wealth screening’

To ensure that our communications are relevant to you and your interests and to assess your likely ability to make, and interest in making, donations to Unlimit Health, we may use additional information such as geographical information and measures of affluence where available from external sources to assist us. This will be a combination of publicly available information, for example drawn from company resources and news media, with what you have provided to us, such as past donations and career information. We may use the services of external screening/profiling companies, and publicly available data from social media sites like LinkedIn, Facebook and Twitter, depending on your privacy settings and/or interaction with us.

3.7.1 This may be carried out by automated or manual processes and enables us to better understand you as our supporter and make appropriate requests for support. A list of publicly available sources of information used by Unlimit Health for the purposes detailed is available on request.

3.7.2 If you do not wish Unlimit Health to undertake this activity, please email our Data Protection Compliance Manager at dpo@unlimithealth.org

3.7.3 Please note that before seeking or accepting donations of £10,000 and above we are required to conduct a minimum level of due diligence, including reviewing publicly available personal data relating to criminal convictions and offences. Due diligence is conducted in accordance with the Unlimit Health Fundraising Policy and Counter Fraud, Anti-Bribery and Anti-corruption Policy.

4. How is your personal information collected?

4.1 We collect most of the personal information about you through direct interactions with you while you are making a donation, and/or subscribing to a mailing list.

4.2 Automated technologies or interactions – As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, serverlogs and other similar technologies.

4.3 Third parties or publicly available sources – We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties: analytics providers, advertising networks and search information providers;

• Contact, Financial and Transaction Data from providers of technical and payment services;

• Identity and Contact Data from data brokers or aggregates;

• Identity and Contact Data from publicly available sources such as Companies House.

5. How we use information about you and the legal basis for processing your data under the GDPR

5.1 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• where we need to perform the contract we have entered into with you or in order to take steps at your request prior to the entry into a contract;*

• where we need to comply with a legal obligation;**

• where it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;***

• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;****

• where it is necessary in order to protect your vital interests or someone else’s vital interests;*****

• where you have consented to the processing.******

5.2 In the next section we have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information.

6. Situations in which we use your personal information

6.1 We need all the categories of information included in paragraph 3 of this policy primarily to allow us to perform our contract with you(*), as part of a process in providing you a service which you have requested(******) and to enable us to comply with legal obligations(**). In some cases, we may use your personal information to pursue legitimate interests of ours, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed in paragraph 6.2 of this policy.

6.2 This data is used by Unlimit Health to support a full range of activities for and in relation to our supporters. These include:

• providing you with information about our work and our activities. This might include sending you publications, e-newsletters, invitations to events and details of fundraising opportunities (****);

• conducting surveys, focus groups and other research (****);

• internal record keeping, including the management of any feedback or complaints (******);

• administrative purposes e.g.regarding a donation you have made or an event you have registered for or attended (*);

• furthering our charitable objectives, including to help us raise money or by asking you to donate money to Unlimit Health (****);

• transferring to HM Revenue and Customs in respect of any Gift Aid claims (**);

• wealth screening, profiling and research to gain a better understanding of our supporters, inform our fundraising strategy and target our communications more effectively and appropriately (****); and

• to sending you our newsletter or information about the work of Unlimit Health as further explained in paragraph 7 of this policy (******).

6.3 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.