Purple Warriors (“The Charity”) Privacy Policy

Date of Policy March 2023

We are Purple Warriors, a charity dedicated to the preservation and protection of the physical and mental health of serving and retired members of HM Forces who have some form of physical or psychological impairment as a result of their service. We do this by providing and assisting in the provision of opportunities to take part in the sport of dragon boating.

Within this Privacy Policy “Our”, “Us” and “We” mean Purple Warriors, registered charity number 1169153  in England and Wales.

Purple Warriors is committed to protecting and respecting your privacy. This policy outlines how we will use any personal information that you provide to us.

If you have any questions about this privacy policy or our privacy practices, please contact:

Name: Sarah McBride
Address: 132A College Road
Phone Number: 07811339936
E-mail: dpo@purplewarriors.org

The type of personal information we collect

We currently collect and process the following information:

  • Personal information for example, your name title, date of birth and gender;
  • Contact Information includes your address, email address and telephone numbers;
  • Financial Information includes bank account details and payment card details; 
  • Transaction Information includes data provided to manage membership, associate membership, membership communications, participation in training or racing and provision of information;
  • Technical Information includes internet protocol (IP) address, login information, browser plug in types and version, and information analytics to improve our website, marketing, and experiences;
  • Usage Information includes information about how you use our website;
  • Communications Information includes your preferences in how you wish to receive communications from us and your communication preferences.
  • Special category data includes data concerning health including any disabilities our member or participants may have to carry our charitable activities with appropriate safeguards

How we get the personal information and why we have it

We will only use your personal information when the law allows us to. Under the UK General Data Protection Regulation (UK GDPR), the lawful basis’ we rely on for processing information are: 

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting the Data Protection Officer 

(b) We have a contractual obligation with you. The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract

(c) We have a legal obligation. the processing is necessary for us to comply with the law (not including contractual obligations).

(f) We have a legitimate interest.  the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the an individual’s personal data which overrides those legitimate interests. 

We will only use your personal information for the purposes for which we collect it, unless we reasonably believe that we need to use it for another reason and that reason is similar with the initial intention.

You may give us your identity, contact and financial information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you: 

  • register as a member;
  • subscribe to hear more about our training or to our newsletters;
  • express an interest in any of our programmes, membership, training;

Special Category Data will only be collected from members or from those who have regular contact with the Charity in connection with our charitable purposes.  This data shall not be disclosed outside of the Charity without the consent of the data subjects.

We have defined below how we plan to use your personal information, and which of the legal basis we shall rely on to do so. We have also outlined our legitimate interests where relevant.

Purpose Type of Personal information Lawful basis for processing including basis of legitimate interest
To register you as a member, associate, family member, user of any of our activities e.g., attending a training session (a) Personal

(b) Contact

(a) Essential to perform our contract with you.

(b) Essential to achieve our legitimate interests (we need to be able to communicate with beneficiaries/members/users of our services/activities for specific purposes)

To assess and register those eligible to be full members and to comply with the objects of the charity;

To understand members’ and participants’ needs to help fulfil our charitable objectives.

  1. Personal
  1. Special Category Data 
  1. Essential to achieve our legitimate interests (we need to collect health data to comply with our charity’s objects and ensure accessible facilities for members and participants)*
To manage membership, communications, participation in training or races and provision of information and any other services including:

  1. Communicate our activities
  1. Manage payments, and fees 
  1. Collect  any money that may be owed to us
(a) Personal

(b) Contact

(c) Financial

(d) Transaction

(e) Communications

(a) Essential to perform our contract with you.

(b) Essential to achieve our legitimate interests (we need to be able to communicate with beneficiaries/users of our services/activities for specific purposes)

To manage our relationship with you which will include:

  1. Notifying you about changes such as changes to our terms or privacy policy or to any other policy
  1. Asking you to reply to a Spond or Mail Chimp survey
(a) Personal

(b) Contact

(c) Profile

(d) Communications

(a) Essential to perform our contract with you.

(b) Essential to comply with a legal obligation;

(c) Essential for our legitimate interests (to ensure our records are correct and up to date)

To send our newsletter to you or information regarding our services if you have provided consent and subscribed to receive these 
  1. Personal
  1. Communications

(c) Contact

Consent
To register you as an emergency contact of a member, associate member or any users of our services or participants at training or races. (a) Personal

(b) Contact

Essential for our legitimate interests (to ensure we have a contact in case of emergency)
To manage any donations and gift aid (if included)  (a) Personal

(b) Contact

(c) Financial

Essential for our legitimate interests (knowing who our donors are)

Essential to comply with a legal obligation (gift aid details)

To film and photograph training for website, marketing and coaching  Personal Consent 
To use data  analytics to enhance our website, marketing, partner relationships and experiences (a) Personal

(b) Technical

(c) Usage

Essential for our legitimate interests (to keep our website up to date and relevant, to improve our strategy )
  • We use Legitimate Interest as our lawful basis for processing Special Category Data and as a Not for Profit the charity meets the “conditions for processing special category data” as outlined in Article 9 of the UK GDPR

When you navigate our website, we will automatically collect Technical Information about your devices, browsing behaviours and patterns. We collect this personal information through the use of cookies and other similar tools. We may also obtain Technical Information about you if you visit other websites using our cookies. Please see our cookie policy.

You can adjust your browser to reject all or some browser cookies, or to notify you when websites access cookies. If you deactivate or reject cookies, some parts of this website may not be accessible or may not operate properly. For more information about the cookies we use, please see our cookie policy.

Third parties

We will obtain personal information about you from several third parties as set out below: 

  • Contact, Financial and Transaction Information from providers of technical, payment services and Personal and Contact Information from information providers based outside of the EU;
  •  Personal and Contact Information from government and regulatory bodies such as The Charity Commission and the Disclosure and Barring Service;
  • Governing Bodies such as the British Dragon Boat Association;
  • Online marketing providers such as Mail Chimp (based outside of the EU).

We may share information we collect about you with: 

  • Professional advisers including banks, accountants, and insurers based in the UK who may provide banking, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who may require reporting of processing activities.
  •  Website Services and IT solutions
  • Participating organisations who participate in our training
  • Marketing and survey providers such as MailChimp
  • Government bodies such as the Disclosure Barring Service

We expect all third parties to protect your personal information and to treat it in accordance with  privacy law. We do not permit  third-party service providers to use your personal data  for their own purposes. They may only process your personal information for specific purposes and according to our instructions.

How we store your personal data

We will only store your personal data for as long as is reasonably necessary and for the purposes for which we collected it, including any need to comply with legal, regulatory, tax, accounting or reporting requirements. We may store your personal data for longer if we have a complaint or if we believe that there may potentially be any legal action regarding  our relationship with you.

The applicable retention period for which we store personal data will depend on the nature and sensitivity of the personal information, as well as the possibility of any harm from unauthorised use or disclosure. We also consider the purposes for which we process your personal information and any other relevant legal, regulatory, tax, accounting or obligations, and whether we can achieve those purposes through other methods, 

In some instances, we are required to keep specific information about our members or users of our services (including Contact, Identity, Financial and Transaction Information) for six years after they cease their relationship with us for tax purposes.

You may be able to ask us to delete your data: please refer to your data protection rights section below for further information. We may also anonymise your personal information (so that it can no longer be connected to you) to help improve our services or for statistical purposes, and  we may use this information indefinitely without notifying you.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at dpo@purplewarriors.org if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us using the below details:

Sarah McBride, Secretary, 132A College Road, Bromley, BR1 3PF
Email: secretary@purplewarriors.org

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk