1. Introduction and general terms
- what information The Circle may collect about you;
- how The Circle will use information we collect about you;
- when The Circle may use your details to contact you;
- whether The Circle will disclose your details to anyone else;
- your choices regarding the personal information you provide to us; and
The Circle is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the Data Protection Act 1998 and the Privacy & Electronic Communications (EC Directive) Regulations 2003.
2. Who we are
The Circle is a charity registered in England & Wales (1160293) and Scotland (SCO46315) and a company limited by guarantee (08993335). The Circle’s registered address is Merchant House, 30 Cloth Market, Newcastle Upon Tyne, NE1 1EE.
3. What information will The Circle collect about me?
When you contact The Circle to become a member, make a donation or sign up to any of The Circle’s activities or online content, such as newsletters or you telephone, email or write to The Circle, or engage with The Circle via social media channels, we may receive and retain personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, bank account details to process donations and whether or not you are a tax payer so that we can claim Gift Aid.
By submitting your details, you enable The Circle (and where applicable any sub-contractors we may use) to raise funds and to provide you with the goods, services, information, activities or online content you select.
We do not usually ask members to provide “sensitive personal data” (such as information relating to racial or ethnic origin, religious beliefs, sexual orientation, health information and political opinions). However, if you reveal such information in emails or other communications hosted by our site, you are consenting to this sensitive personal data being collected and processed by us. If you do not wish to consent, please do not include sensitive personal data in your communications to, or through, the site.
If there is a clear reason for collecting sensitive personal data, for example if you are participating in a marathon or similar fundraising event or where we need this to ensure that we provide appropriate facilities or support to enable you to participate in the event. Clear notices will be provided on applications for such events so that it is clear what information we need and why we need it.
If you are simply browsing the site as an anonymous visitor, The Circle may still collect certain information from you, such as your IP addresses (an IP address is a number that can uniquely identify a specific computer or other network device on the internet).
If you enter your contact details in one of our online forms, we may use this information to contact you even if you don’t “send” or “submit” the form. We will only do this to see if we can help with any problems you might be experiencing with the form or with our websites.
We may combine the information we collect about you and the information you give to us with information we receive from other sources.
4. How will The Circle use the information it collects about me?
The Circle will use your personal information for a number of purposes including the following:
- in relation to any correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means;
- for “service administration purposes”, which means that The Circle may contact you for reasons related to donations you have made such as your tax status with regard to Gift Aid, the completion of commercial or other transactions you have entered into with The Circle or the activity or online content you have signed up for;
- for internal record keeping, to administer the site and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
- for wealth screening activity;
- to fulfil sales contracts you have entered into with The Circle;
- to contact you about any content you provide;
- to invite you to participate in surveys or research about The Circle or our work (participation is always voluntary);
- for marketing purposes where you have specifically consented to receive marketing communications from us (see below);
- to provide you with information about our activities or online content you have agreed to receive;
- to personalise the way The Circle content is presented to you;
- to use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries;
- to analyse and improve the activities and content offered by the site and to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes;
to notify you about changes to our service; and
- as part of our efforts to keep our site safe and secure.
5. Will I be contacted for marketing purposes?
The Circle will only contact you for marketing purposes where you have provided us with freely given consent to do so. You may provide that consent in various ways including though online or paper forms, responding to television adverts (where consent statements are clearly visible) or face-to-face though engagement with our staff.
Please see section  below for information on how to change your communication preferences, including opting out of future marketing communications.
6. Personal information submitted when you make a donation or purchase a ticket
We will collect your first and last name, and your email address, when you make a donation or purchase a ticket using our site. When you make a card payment your credit or debit card details are only collected by our third party payment provider – PayPal. We do not store your credit or debit card details.
If you choose to claim Gift Aid on your donation we will also collect your declaration of tax status and your home address.
7. Will The Circle share my personal information with anyone else?
We will only use your information for the purposes for which it was obtained. We may share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
The Circle will not, under any circumstances, share or sell your personal data with any third party for marketing purposes and you will not receive offers from other companies or organisations as a result of giving your details to us.
We may share your information with selected third parties, including “data processors” such as our service providers, wealth screening companies, associated organisations and agents who help us to prepare and send the materials relating to our projects and fundraising activities. These “data processors” will only act under our instruction and we will not allow these organisations to use your data for their own purposes and will take care to ensure that they keep your data secure.
We may disclose your information to third parties:
- in the event that we buy or sell any business or assets, in which case we may disclose your personal data to the prospective buyer or seller;
- if The Circle or substantially all of its assets are acquired by a third party, in which case personal data held about members will be one of the transferred assets;
- if disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing); and
- in order to enforce or apply our terms and conditions or to protect the rights, property or safety of The Circle, or our members or others. See Section  for more detail.
8. Offensive or inappropriate content placed on the site
If you post or send offensive, inappropriate or objectionable content to or anywhere on the site or otherwise engage in any disruptive behaviour on any The Circle service, we may use your personal information to stop such behaviour.
Where The Circle reasonably believes that you are or may be in breach of any applicable laws (e.g. because content you have posted may be defamatory), we may use your personal information to inform relevant third parties such as your employer, internet provider or law enforcement agencies about the content and your behaviour.
9. Where we store your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. How long will The Circle keep my personal information?
We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of donations for at least seven years.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Where you contribute material to us, e.g. user generated content or in response to a particular campaign we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.
11. What is The Circle’s policy on allowing me to update, correct, or delete my personal information?
The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest. If you wish to change how we communicate with you, or update the information we hold, then please contact us. You may:
email us at [email protected]; or
write to us at: The Circle, Merchant House, 30 Cloth Market, Newcastle Upon Tyne, NE1 1EE.
You may also opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from The Circle.
Under the Data Protection Act you have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. (We charge £10 for information requests and require you to prove your identity with two pieces of approved identification).
12. Cookies Policy – information The Circle collects from your computer or mobile device
a. What is a cookie?
Cookies are small text files on your device. They are made by your web-browser when you visit a website. Every time you go back to that website, your browser will send the cookie file back to the website’s server. Cookies are useful because they allow a website to recognise a user’s device. Click here or here to find more information about cookies.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience.
They can also help to ensure that adverts you see online are more relevant to you and your interests.
Information supplied in cookies also allows us to measure the effectiveness of online marketing campaigns for The Circle. This enables us to ensure any money we spend on digital marketing gives us a good return on investment.