‘Agent(s)’ refers to Employees, Trustees, Volunteers, Contractors and/or Sub-Contractors.
‘Charity Objectives’ refers to the aims set out in our constitution, and incorporation documents. Our aims can be viewed in about us, http://www.drinklink.org/about/ or http://www.mydrinklink.org/who-are-we/.
‘Compliance Officer(s)’ refers to an appointed agent to oversee compliance of the Data Protection Policy.
‘Data Controller’ refers to Data Protection Act 1998 Section1 definition.
‘Data’ refers to the anonymous and/or personal data.
‘Data’ Subject’ refers to Data Protection Act 1998 Section1 definition.
‘DRiNKLiNK Business’ refer to (1) those in the course of discharging their duties on behalf of DRiNKLiNK to meet DRiNKLiNK charitable objectives.
‘Navigation path’ refers to: navigating our website and pages visited within our website.
‘Our’ or ‘Us’ or ‘We’ refers to DRiNKLiNK SCIO and its agent’s, a register Scottish Charity with a designated charity registration number, SC043205.
‘Personal Data’ refers to Data Protection Act 1998 Section1 definition.
‘Personal Sensitive Data’ refers to Data Protection Act 1998 Section 2 definition.
‘Policy’ refers to Privacy Statement.
‘SCIO’ refers to Scottish Charitable Incorporated Organisation.
‘Subscribed Services’ refers to email notification, newsletter’s and/or services operated by us.
‘Subscriber’ refers to any one that participates in any of our subscribed services.
‘UK’ refers to United Kingdom and Great Brittan and Northern Ireland.
‘Website’ refers to www.drinklink.org or www.mydrinklink.org and subscribed services operated by us.
‘You’ refers to a subscriber or to some other person who visits any of our Websites.
It is the responsibility of all agent’s acting on behalf of DRiNKLiNK to abide by this policy. This policy will be focused on collecting, storing and processing information about you using and/or visiting our website.
3. Policy Statement
While using our website, you agree that we may collect, store and process your data as prescribed within this policy, below. If you disagree with the prescribed methods of collection and processing of your data while using our website, please leave the website immediately.
3.1. Collection of Data
We at our discretion may collect and store the following data:
Specific information relating to your device accessing our website, about your visits to and use of our website, including:
- IP address;
- Geographical location;
- Browser information;
- Operating system operation;
- Device hardware information;
- Referral source;
- Length of visit;
- Pages viewed;
- Website navigation paths;
- Frequency of visits and/or navigation path;
- Pattern of service use and/or navigation path;
- Timing of visits and/or navigation path;
- Cookies, See cookies policy;
Data provided by you to us when registering with our website, including:
- Email address;
- Postal Address and Postcode;
- Contact Telephone or mobile Number;
- Date of Birth and age;
- User ID and Password;
- Relationship status;
- Employment Details;
Data contained in or relating to any communication that you send us through our website or enquiries about our website or enquires which are be connected with subscribed services through our website, including:
- Content of the communication;
- Metadata in connection with the communication;
When disclosing third party data to us through our website or our website subscribed services, you must obtain the third party consent to allow us to collect and process data disclosed about that third party.
3.2. Processing of Data
We may process data and store the result of the processing data that we have obtained with your consent as prescribed, above, for the purpose specified below:
We may process data of the following:
- Conduct effective administration of our website and charity objectives;
- Personalise our website to you;
- Enable your use of the subscribed services available on our website;
- Source and/or market to you subscribed services offered through our website, in accordance with our charity objectives;
- Source and/or market to you, services offered from selected third parties, which we believe will enhance your experience of our website and/or may be of interest to you, and in accordance with our charity objectives;
- Source to you non-marketing commercial communications;
- Perform anonymous statistical analysis of data which has been collected about our users and where appropriate provide this data to third parties, in accordance with our charity objectives;
- Process complaints and/or enquires made by you relating to our website and/or subscribed services;
- Keep our website and data secure and prevent nefarious collection and/or processing of data;
- To conduct compliance with the governing laws of the UK;
- Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.3. Disclosure of Data
We at our discretion insofar as reasonably essential for the purposes set out in this policy, disclose your data to any of our employees; volunteers; trustees; officers; insurers; professional advisers; agents; supplier’s; contractors or subcontractors.
We may disclose data so far as permitted by law to: exercise, pursue and defend any legal actions and/or rights.
Where to the contrary, there is no obligation/ duty/ right/ consent to disclose data collected, stored and process by us, we must obtain expressed consent, however, we may disclose data which cannot be used to identify an identifiable individual: for example statistical data which would be absent of any identifying personal data.
3.4. Security of data
While we take reasonable care to make sure your data is secure, however, we cannot provide securing and assurance that while you transmit data to us through our website or any communication as prescribed above can be secure.
While we do not currently posses physical servers; we do store your data on third party suppliers which have been selected that conform to this policy.
3.5. Changes to our Privacy Statement
Data privacy and internet usage is constantly changing and we must develop this policy from time to time to conform to best practice to endeavour to make sure your data is secure; collected and processed lawfully.
3.6. International transfer of Data
Personal data that we collect, store and process as detailed in this policy, may be transferred between any country we operate or may be transferred to countries- outside of the European Union or European Economic Area.
Personal data that we collect, store and process may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Union and/or European Economic Area:
Personal data that you publish on our website or submit for publication on our website, for the consumption of the wider public view, may be available around the world, via the internet. We cannot prevent the use or misuse of such information by others.
3.7. Third Party Websites
We provide additional resources including third party websites to enrich your experience while using our website. We cannot be held responsible for third party websites and their practice of collecting; processing and storing your data. It is your responsible to check each third parties’ own Privacy Statement.
3.8. Subject Access Request and Modifications of Data
You may at any time personalise and/or modify data we hold by changing it while using our website. There will be at times that some data will not be available to change while using our website.
You have a legal right to request the following in connectioin with data we hold about you:
- To Modify data;
- To review data;
To enforce the above rights, you must write to us requesting the enforcement of such rights. We may withhold processing your request until the following provisions have been conducted:
- Clear instruction of what data you wish to review; and/or;
- Clear instructions of what data you wish changed and an explanation why you believe it should be changed; and
- Provide satisfactory identification to verify your indent; which should include a utility bill; or bank statement displaying your current address; and
- Payment of the processing fee of £10.00, for request to review data – not to modify data;
3.9. Any Queries Contact:
Contact Name: Compliance Officer
4. Related References
Data protection Act 1998 c. 29
Privacy and Electronic Communications (EC Directive) Regulations 2003 No. 2426
Information Commissioner's Office
You should be aware that when you use our websites, mobile sites, or mobile apps, we may collect information by using ‘cookies’.
What are cookies and how do they work?
Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen.
Cookies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites. There are many different uses for cookies, but they fall into four main groups:
(i) Cookies that are needed to provide the service you have asked for
Some cookies are essential so you can move around the website and use its features. Without these cookies, services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.
Here are some examples of essential cookies:
(ii) Improving your browsing experience
- Keeping you logged in during your visit; without cookies you might have to log in on every page you go to.
- When you add something to the online shopping basket, cookies make sure it’s still there when you get to the checkout.
- Some are session cookies which make it possible to navigate through the website smoothly. However these are automatically deleted after you close your web browser.
These cookies allow the website to remember choices you make, such as your language or region and they provide improved features.
Here are a few examples of just some of the ways that cookies are used to improve your experience on our websites:
- Remembering your preferences and settings, including marketing preferences.
- Remembering if you’ve filled in a survey, so you’re not asked to do it again.
- Remembering if you’ve been to the site before. If you are a first-time user, you might see different content to a regular user.
- Restricting the number of times you’re shown a particular advertisment. This is sometimes called ‘frequency capping’.
- Showing you information that’s relevant to products of ours that you have.
- Enabling social media components, like Facebook or Twitter.
- Showing ‘related article’ links that are relevant to the page you’re looking at.
- Remembering a location you’ve entered such as weather forecasts.
We like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our sites and if they get ‘error messages’ from web pages.
This group of cookies, often called ‘analytics cookies’ are used to gather this information. These cookies don’t collect information that identifies you. The information collected is anonymous and is grouped with the information from everyone else’s cookies. We can then see the overall patterns of usage rather than any one person’s activity. Analytics cookies only record activity on the site you are on and they are only used to improve how a website works.
Some of our websites and some of the emails you might get from us also contain small invisible images known as ‘web beacons’ or ‘tracking pixels’. These are used to count the number of times the page or email has been viewed and allows us to measure the effectiveness of its marketing and emails. These web beacons are anonymous and don’t contain or collect any information that identifies you.
We also use ‘affiliate’ cookies. Some of our web pages will contain promotional links to other companies’ sites. If you follow one of these links and then register with or buy something from that other site, a cookie is sometimes used to tell that other site that you came from one of our sites. That other site may then pay us a small amount for the successful referral. This works using a cookie. Learn how to manage your analytics cookies.
(iv) Showing advertising that is relevant to your interests
We sell space on some of our sites to advertisers. The resulting adverts often contain cookies. The advertiser uses the browsing information collected from these cookies to:
- restrict the number of times you see the same ad (frequency capping);
- and help show other ads that are relevant to you while you’re on our websites. This is often called online behavioural advertising (OBA). OBA is a way of using information about your web-browsing activity, collected by using cookies, to group you with other users into interest groups and show you advertisements based on those interests. The OBA data collected from cookies you get when you’re on our sites is only used to show relevant ads on our sites, not on other websites.
So how does OBA work? Let’s look at an example. Imagine you visit a website about travel. That website shows an advert and with that advert you receive a cookie. Imagine you then visit one of our websites which has an advert from the same advertiser you saw on the travel site. The advertiser will give you a new version of the cookie you received on the travel site. The advertiser can then use that cookie to recognise that you’ve previously been to a travel site and show you a relevant ad.
Although the OBA data collected uses your browsing activity to understand your interests, the data is anonymous and isn’t linked to you as a person. Even if you log in to our websites, the OBA data is still not linked to you.
Neither we, nor the companies who show ads on our sites sell data collected from cookies to any other organisations.
A Device Identifier is a tool with an equivalent function to that of a cookie which is used to target and track the effectiveness of content and advertising delivered to users of our mobile applications.
You can reset your Device Identifier at any time through the Advertising settings on your iPhone, or opt out of sending this information by setting the ‘Limit Ad Tracking’ option located in the on your iPhone.