Privacy Notice
## 1. Who we are
Welcome to the Privacy Notice of now-u, a community interest company (“CIC”) incorporated in England and Wales (Registration Number 12709184).
now-u CIC operates a mobile application (“App”) that hosts materials curated by the now-u community charity to inform, involve and inspire people to drive positive change for charitable causes that they care about. now-u CIC also runs a website, now-u.com, which provides information about the App and charitable campaigns.
By using the terms “we”, “us” or “our” throughout this Privacy Notice we are referring to now-u CIC. Where we say ‘third party’ this means anyone who is not you or us. This could be another person or an organisation.
2. What is this Privacy Notice about?
This Privacy Notice explains how we handle your personal information when you visit our website, when you get in touch with us (through the website or by any other means), when you sign up to or use our App, or when you subscribe to any of the services we offer. This Notice is separate from our Cookies Policy, which is also available on our website. It contains some important information and we encourage you to read it carefully.
This Privacy Notice does not apply to the personal information which you provide to us and/or we collect from you or a third party when you apply for a role with us or when you join us as a volunteer. In those circumstances, our Volunteer Privacy Notice, which we would send to you in due course, would apply.
Our website and the App may contain links to third party websites. We encourage you to read the privacy notice of each of those websites you access, as this Privacy Notice only applies to our website, the App and the services we offer.
Our services, whether those offered through our website, the App or otherwise are aimed at people aged 16 and over and we do not knowingly collect any personal information relating to children.
3. What personal information do we collect?
We may collect, use and store different kinds of personal information about you. The table below sets out each activity in which we collect your personal information, what personal information we collect and the reasons why we collect this information.
| Activity | Personal information now-u collects | Reasons why now-u collects this personal information |
|---|---|---|
| Creating a now-u App user account | - Name <br/>- Email address <br/>- App usage statistics | - Create account -Understand how our App is performing -Identify bugs and where we need to focus our efforts to improve |
| Voluntarily inputting personal information into your now-u App user account | - Age -Location - Voting constituency | - Improve user experience (e.g., connecting users with local charitable campaigns) -Analyse participation in campaigns and other usage statistics |
| Signing up to the now-u newsletter | - Name - Email address | - Add to newsletter mailing list |
| Participating in now-u App user testing | - Name - Email address | - Contact about testing participation |
| Voluntarily providing personal information as part of now-u App user testing | - Age -Gender - Occupation | - Better understand the demographic characteristics of our user base, with the aim of tailoring our product and marketing strategy accordingly |
| Getting in touch with us by email through [email protected] or via Facebook, Twitter, Instagram or Linkedin | - Name - Email address - Any other personal information you provide to us | - To respond to your query or request |
4. How do we collect your personal information?
We collect most of your personal information directly from you; through any of the following channels:
- Creating an App user account
- Inputting your personal information into your App user profile on our App
- Signing up to receive emails from us
- Participating in our App user testing
- Getting in touch with us by email through [email protected]
- Getting in touch with us via Facebook, Twitter, Instagram or Linkedin
We may also receive your personal information indirectly from other sources or third parties by monitoring how users engage with our App and the website through our use of cookies, as set out below.
Cookies
Our website and App use cookies. A cookie is an online technology to collect information about you and to store your online preferences. Cookies are small pieces of information sent by a web server to a web browser which allow the server to uniquely identify the browser on each page.
Our website uses Google Analytics, Google Tag Manager and Facebook Tracking Pixel. Our App uses Google Analytics only.
We have integrated these tools to enable us to evaluate user behaviour and establish links with other websites. More information on how our website and the App use cookies is available in our Cookie Policy.
5. How and why do we use your personal information?
We collect and use your personal data in accordance with the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) and the Data Protection Act 2018 (“DPA 2018”) where either you have given us your consent to do so, which you can withdraw at any time, or where it is necessary for any of the following reasons:
- For the performance of our contract with you as part of your use of our App, its associated services or any other services we offer; or
- For a legitimate interest pursued either by us or a third party, as long as that interest is not overridden by your rights and freedoms.
We set out below a description of the ways we plan to use your personal information, and the legal basis upon which we rely to do so. We have also provided a description of the legitimate interests we rely on, where this applies.
Performance of a contract
When you set up and use our App the personal information which we collect and use is necessary for you to use the App and its associated services. We require your name and email address to set up your App user account.
Legitimate interest
In responding to an email you have sent to us through [email protected], or any communication or message you send to us via Facebook, Twitter, Instagram or Linkedin, we also rely on our legitimate interest; that is to maintain our relationship with you.
Consent
When you voluntarily provide additional personal information as part of creating your now-u App user account or participating in our user testing, you consent to us collecting and using that information. If you have signed up to our newsletter, then you have given us your consent to receive them. You have the right to withdraw your consent at any time by contacting us at dataprotection@now-u.com.
6. Who are the recipients of your personal information?
We will not share your personal information with anyone outside of the relevant members of the now-u team, unless we are required to do so under applicable law.
7. How long do we keep your personal information
If we have collected your personal information in order to enable you to create an App user account, we will keep it for until and unless you decide to deactivate your user account, unless we are required by applicable law to keep your personal information for longer.
If you have signed up to our mailing list, we will keep your name and email address for as long as now-u is operating, or until you unsubscribe or withdraw your consent.
If you have signed up to participate in our App user testing, we will keep the personal information you have provided for as long as now-u is analysing user testing data, unless or until you make a request for your user information to be removed from our records. Once we have finished analysing our user testing data and completed any follow-up enquiries, we will delete your personal information, but retain your feedback in an anonymised form.
8. Do we transfer your personal information outside of the EU?
All of your personal information is stored in digital form, either in limited-access Google Workspace folders, in Mailchimp, in HubSpot or on the now-u database. In cases where one of our providers is based outside of the EU, we will have appropriate measures and safeguards in place as required by the GDPR and DPA 2018.
9. Your data protection rights
Under certain circumstances, you have rights under the GDPR and DPA 2018 in relation to your personal information. You have the following rights:
Right to request access to your personal information. This right enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
Right to request correction of the personal information we hold about you. This right enables you to have any inaccurate data we hold about you corrected. We may however need to verify the accuracy of the new data you provide to us.
Right to be forgotten (this is also known as the right to request erasure of your personal data). This right enables you to request from us to delete or remove personal information provided this is permitted by applicable data protection laws.
Right to object to the processing of your personal information when we rely on legitimate interest pursued by us or a third party or when we are processing your personal data for marketing purposes. In some of those circumstances however, and after conducting our own legitimate interest assessment, we may be able to show that there are compelling legitimate grounds to process your personal data that override your rights and freedoms.
Right to request restriction of processing of your personal information. This right enables you to restrict or suspend the processing of your personal data in certain circumstances.
Right to request data portability of the personal information we have about you. This right enables you to request the personal data we hold about you to be sent to you or a third party of your choice in a structured, commonly used, machine-readable format.
Where we rely on consent as the legal basis for processing your personal data, you have the right to withdraw that consent at any time.
More information about your rights under the (EU) General Data Protection Regulation (GDPR) is available here.
If you wish to exercise any of the rights set out above, please contact us at [email protected]. If you wish to contact us by post, please send your correspondence to the following:
Lizzie Elgar
now-u CIC
Registered Address: 2 Granville Road, Sevenoaks, Kent, United Kingdom TN13 1ER.
We will respond to your request as soon as possible and in any event within one month of the date we receive your request.
We do not charge any fee for dealing with or responding to your request. We may however charge a reasonable fee if your request is excessive, repetitive or clearly unfounded.
You have the right to lodge a complaint with the ICO. More information about the contact details of the ICO and how to lodge a complaint is available here.
10. Changes to our Privacy Notice
We may periodically change this Privacy Notice as necessary, for example, if the legal requirements are updated, or if we change how now-u operates in any way that may impact collection of personal information. If we update our Privacy Notice, we will post the updated version on our website. We will also make the updated version accessible through the app, and make a note of the change in the app store.
If we materially change the way in which we process your personal information, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes.
This Privacy Notice was last modified in August 2023.
Community Interest Company (12709184) and Charitable Incorporated Organisation (1196568)