ACTIS ACTS - PRIVACY POLICY

  1. INTRODUCTION

    1. This privacy policy (“Privacy Policy”) explains how Actis Acts CIO (registered charity number 1176455) (“Actis Acts”) processes personal information of our Website visitors and contact. It also explains how you can instruct us if you prefer to limit that use of that information; what procedures we have in place to safeguard your privacy; and the cookies we may use and send to your computer or mobile device.
    2. This Privacy Policy should be read in conjunction with the Website Terms of Use of which it forms part and which also apply when you visit www.actisacts.org (“Website”). If you do not agree with this Privacy Policy, you must not use the Website or submit information to us through or in connection with the Website.

  2. WHAT PERSONAL INFORMATION DO WE HOLD ABOUT YOU

    1. Personal information means any information that we hold about you from which you can be identified either directly or indirectly.
    2. We will collect and store your personal information when you interact with our Website or when you contact Actis Acts. We collect personal information in writing, by telephone and by email.  This includes your name, postal address, email address, IP address, telephone number and any other personal information you provide if you contact us.
    3. We will take reasonable steps to keep the personal information that we store accurate and where necessary up to date. If you consider that any of the personal information that Actis Acts holds about you is incorrect please notify us, see Contact Information in paragraph 16 below.

  3. HOW WE USE YOUR INFORMATION

    1. We will use your personal data, and may share your personal data with other parties acting on our behalf, for one or more of the following purposes:
      1. dealing with your enquiries and requests;
      2. ensuring the security of our organisation, preventing or detecting fraud or abuses of our Website;
      3. enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing (where applicable), verification, technical, logistical or other functions;
      4. developing and improving our offering, for example, by reviewing visits to our Website and its various subpages and to conduct research about the use of our Website;
      5. for our own administrative purposes or conducting internal audits;
      6. protecting our legal rights and interests and resolving any disputes; and
      7. to comply with applicable law.
    2. We will not sell your personal information to others. If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law.

  4. INFORMATION FOR MARKETING PURPOSES

    We may use your information to send you updates and news concerning Actis Acts and its activities and events which we feel may be of interest to you. If at any time you wish us to stop using your information for these purposes, please notify Actis Acts using the Contact Information in paragraph 16 below.

  5. GROUNDS FOR PROCESSING

    1. In order to store, hold and process your data lawfully we rely on one or more of the following legal grounds:
      1. your consent to particular processing activities; or  
      2. our legitimate interests as a charity. For example, it is within our legitimate interests to use your personal data to prevent or detect fraud or abuses of our Website;
      3. our compliance with a legal obligation to which Actis Acts is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
      4. if you are a party to a contract, because processing your personal data is necessary for the performance of that contract.

  6. DISCLOSURE OF YOUR PERSONAL INFORMATION

    1. There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
      1. to our employees and trustees;
      2. to any successors in title to our activities;
      3. to other companies in the Actis group;
      4. to our outsourced third party service providers or suppliers who assist us in operating our Website and running the charity (including but not limited to IT service providers or providers of data storage or security);
      5. to professional advisors such as lawyers and accountants or other consultants;
      6. to legal and regulatory authorities where we are required by law or regulation to do so; and
      7. to any other third party where you have provided your consent.

  7. TRANSFER OF PERSONAL DATA OUTSIDE OF THE UK 

    Actis Acts may transfer your personal data to third parties in countries outside the UK including outside of the EEA for further processing in accordance with the purposes set out in this Privacy Policy. In particular, your personal data may be transferred to our outsourced service providers located abroad, and this may include companies, offices or data centres. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisational, contractual or other lawful means.  Please contact us if you would like more information about how your personal data may be transferred by Actis Acts and the safeguards that we have put in place; see Contact Information in paragraph 16 below.

  8. RETENTION OF PERSONAL INFORMATION

    We will take all reasonable steps to retain personal data only for the duration of the purpose for which it was obtained as set out in this Privacy Policy (unless longer retention is required by the applicable law or regulation). We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

  9. CONFIDENTIALITY AND SECURITY

    1. Actis Acts will take all reasonable steps to:
      1. safeguard all personal information that you provide to us;
      2. ensure that it remains confidential and secure; and
      3. ensure that personal privacy is respected.
    2. All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorised access or disclosure and loss or corruption by computer viruses and other sources of harm.  Please be aware that communications over the Internet, such as emails are not secure unless they have been encrypted.

  10. YOUR RIGHTS WITH REGARDS TO YOUR PERSONAL INFORMATION

    1. Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant data protection authority if they believe that their personal information is not being processed in accordance with the law. Further information is set out below: 
      1. Right to obtain a copy of your personal information. You may have the right to obtain a copy of the personal information we hold about you.
      2. Right to rectification. You may request that we rectify any inaccurate and/or incomplete personal information.  If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy.
      3. Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent.
      4. Right to object to processing. You may request that we stop processing your personal information.
      5. Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
      6. Right to lodge a complaint with the supervisory authority. You have the right to complain about the use of your personal information to the relevant supervisory authority, which in the UK is the Information Commissioner’s Office.
    2. Any request under paragraph 10.1 should be submitted in writing to actisacts@act.is. We would also suggest that you contact us if you have any questions or if you have a complaint in relation to how we process your personal information, see Contact Information in paragraph 16 below. However, you do have the right to contact the relevant supervisory authority as noted above.

  11. LINKS

    Our Website may provide hyperlinks to websites owned and controlled by others. Actis Acts is not responsible and accepts no liability in relation to such websites or their contents or for their privacy practices. You should read any applicable privacy policy on any such website.

  12. THIRD PARTIES

    Where you submit personal information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their personal information, the reason you have provided it, how they can contact us and the terms of this Privacy Policy. You further confirm that they have consented to such collection, use and disclosure.  

  13. COMPLIANCE WITH PRIVACY LAWS

    1. Actis Acts complies with the data protection and privacy laws to which it is subject.  You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them.  You should also be aware that privacy laws in various jurisdictions may change from time to time. 
    2. Except to the extent expressly stated otherwise in this Privacy Policy, Actis Acts accepts no obligations with respect to the handling of personal information other than those mandated by law in any relevant country.

  14. COOKIES

    1. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. This section of the Privacy Policy explains what cookies are, why we use them and what you may do if you wish to restrict, remove or refuse to accept cookies.  By continuing to use this Website, you agree to the use of cookies for the purposes set out in this Privacy Policy.
    2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
    3. We use the following cookies:
      1. Strictly necessary cookies. These are cookies that are required for the operation of our Website.
      2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
      3. Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
    4. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

      Cookie Name

      Purpose

      Duration

      More informationcookiesDirective

      cookiesDirective Used to record user preference in relation to cookies 1 year Used to record cookie acceptance and supress message after accepting cookie use.

      Google Analytics _ga

      Used to distinguish users 2 years

      These cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.

      https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

      Google Analytics _gat

      Used to throttle request rates to maintain Website performance 1 minute

      These cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.

      https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

      Google Analytics _gid

      Used to distinguish users 24 hours

      These cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.

      https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage



    5. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
    6. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

  15. CHANGES TO ACTIS ACTS PRIVACY POLICY

    We reserve the right to change this Privacy Policy at any time and any changes will be posted here, so please check this Privacy Policy for changes each time you access our Website.

  16. CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact us by email at actisacts@act.is.