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.
  • We, WE or WE Charity is a brand that represents the data controllers, Free The Children (UK) and WE Education Limited located at 14 Bowden Street, London, UK, SE11 4DS
  • You and Your means you, the person using the Platform
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    This Policy sets out the ways in which WE collect and use your information when you browse, use or register for our Platforms or use or register for other Services.

    We may update this Policy from time to time and you are responsible for reviewing the most current version of this Policy. This Policy was last amended on the date shown at the end of the Policy. By continuing to use the Platform, you accept any updates to this Policy.

    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. Your Consent

    If you use our Platforms or Services, you agree to the collection, use, disclosure and management of your personal information 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.

    The information we collect 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. 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.

    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 non-personally identifiable 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.

    Cookies. Cookies are small pieces of data that are 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. 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 often 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). If you do this, it may affect your ability to use the Platforms or other websites and applications.

    Types of Cookies:
    Cookie Name What it does Resource Expiry
    STYXKEY-country STYXKEY-country From Pantheon, a cookie to store the User’s 2 character country code for GEO Targetting https://pantheon.io/docs/cookies/ 30 min
    __cfduid __cfduid 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.
    https://support.cloudflare.com/hc/en-us/articles/200170156-What-does-the-Cloudflare-cfduid-cookie-do- 1 year
    _ga _ga This cookie is used to help us count how many people visit the website by identifying whether you’ve visited us before. Used to distinguish users. https://developers.google.com/analytics/
    devguides/collection/analyticsjs/cookie-usage
    5 min
    _gat _gat Used to throttle request rate. This cookie is used to manage the rate at which page view requests are made https://developers.google.com/analytics/
    devguides/collection/analyticsjs/cookie-usage
    5 min
    _gat_SpuTracker _gat_SpuTracker Used to track interactions and impressions of pop up forms in Google Analytics. http://www.pujoljulia.com/cookie-policy.html 5 min
    visitor_id72242 visitor_id72242 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.
    http://www.qubeglobal.ca/cookies/ 10 years

    How long do we keep your personal information?
    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.

    Information that we receive from third parties
    We may also collect personal information about you from third parties where you have consented to such third party sharing your information with us. For example, 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;
  • 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 perform any contracts we have with you (e.g. if you signed up to attend one of our programs or events).
  • if you have agreed to receive them, to send you marketing communications about WE Charity content, products, events and promotions by us, that you might be interested in;
  • 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;
    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
  • consider your application to attend one of our events as a Volunteer, Teacher or Honoured Guest or your application for a scholarship
  • keep our services secure and safe;
  • provide you with location services;
  • protect WE Charity, ME to WE, or others’ rights or property;
  • conduct internal operations (data analysis, troubleshooting, testing and service improvements);
  • measure or understand the effectiveness of content;
  • make suggestions for you and other users of the Platforms; and
  • comply with any legal obligations.
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    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) and ME to WE, 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 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 follow 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 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;
  • where permitted or required by law, court orders, or government regulations.
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    Transfer of your information. 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 (which are part of the Privacy Shield program). As such personal information that you submit to us through the Platforms or otherwise 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.

    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.

    As a registered visitor, WE give you the ability to decide whether or not you want to receive correspondence.

    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.

    7. Accessing Your Personal Information

    You have certain rights in respect of the personal information that we hold about you, including:

  • the right to request access to the information that we hold about you;
  • the right to ask us to make changes to the information we hold about you to ensure that it is accurate and kept up to date; and
  • the right to request that we delete information that we may hold about you.
  • You can exercise the rights set out above by writing to us at the details set out at the end of this Policy. We will likely ask you to prove your identity, just to make sure there is no unauthorised access.

    8. General Terms

    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. 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. 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. About Us

    WE Education Limited is a registered data controller. 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: May 24, 2018