Introduction 

This Privacy Policy explains how personal data is collected and used by The Wild East Charitable Trust (referred to as “WildEast”, “we”, “us”, “our” throughout this Privacy Policy). 

At WildEast, we respect your privacy and are committed to protecting your personal data. We take data protection very seriously and will ensure that we uphold the trust that our pledgees, donors, contacts and others place in us when they provide us with their personal information. 

This Privacy Policy will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us at:  info@wildeast.co.uk

This Privacy Policy contains the following sections: 

1.      Important information 

2.      Data protection principles 

3.      How we collect information about you 

4.      What information we collect and how we use it 

5.      Disclosures of your personal data 

6.      International transfers 

7.      Data security 

8.      Data retention 

9.      Your legal rights 

10.  Glossary 

Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy, including “personal data” and “personal information”. 

1.  Important information 

Purpose of this Privacy Policy 

This Privacy Policy aims to give you information on how WildEast collects and processes your personal data, including any data you may provide when you contact us via e-mail, telephone, post or through social media or any data that you provide through this website (www.wildeast.co.uk) (including when pinning your name on the map). 

Unless expressly stated otherwise, this website is not intended for children and we do not knowingly collect data relating to children. 

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. 

Controller 

WildEast is the “controller” for the purposes of data protection law, and is therefore responsible for your personal data. 

As part of our commitment to you, we have appointed a data compliance manager who is responsible for overseeing questions in relation to this Privacy Policy and WildEast’s data protection compliance in general. 

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see section 10 below), please contact the data compliance manager using the following details: 

Contact details 

E-mail address: info@wildeast.co.uk 

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the Privacy Policy and your duty to inform us of changes 

This version was last updated on 9th August 2024. 

We keep this Privacy Policy under regular review and may amend it from time to time. Please check back regularly to view the latest version. Hard copies of this Privacy Policy are available from us on request. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

2. Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy or notice of every website you visit. 

3. Data protection principles 

WildEast adheres to the principles set out in data protection legislation when handling personal data. These principles require personal data to be: 

•          Processed lawfully, fairly and in a transparent manner. 

•          Collected only for specified, explicit and legitimate purposes. 

•          Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. 

•          Accurate and where necessary kept up to date. 

•          Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed. 

•          Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. 

•          Not transferred to another country without appropriate safeguards being in place. 

•          Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data. 

•          Each individual pledgee owns their own data. Any supporter can remove their data from the Map of Dreams at any time by  either emailing info@wildeast.co.uk or removing "mypledge@wildeast.co.uk" from their Land App map. 

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above. 

4. How we collect information about you 

We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when you: 

•          show your support (sign up to the map, pledge time, money, land or other involvement); 

•          provide information to include on our “Map of Dreams”; 

•          subscribe to our newsletter; 

•          request any of our educational services; 

•          respond to a survey; 

• submit a business or destination listing to our Live directory

•          request information from us about our operations; 

•          contact us via e-mail, telephone, post or through social media; and/or 

•          submit an enquiry or message to us. 

Personal data is usually collected from you through direct interaction with us (either in person, by phone, by e-mail, by post, via social media or through this website). For example, you will provide your personal information when you pledge time, money or land to WildEast. 

We may collect personal data from our partners, third parties or from other businesses or sub-contractors that we work with and collect personal data about you, who have provided your personal information to us, either with your consent or on some other lawful basis. 

We may also collect personal data when you use this website, through automated technologies, analytics providers or search engine providers. We use cookies to assist the site running as effectively as possible. To find out more about cookies, or to learn how to change your preferences, click here. 

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of any contract with you, and you fail to provide that data when requested, we may not be able to continue our relationship with you. 

5. What information we collect and how we use it 

The personal data that we may collect will include: 

•          Contact details including your name, address, telephone number, e-mail address and social media details; 

•          Payment information, including credit/debit card details and bank account details; 

•          Contact history, such as any communications with us by telephone, e-mail, post, through our website or via social media; 

•          Donation history, including information about any previous pledges; 

•          Photographs and video footage, if you upload an image or video of you as part of your pledge; 

•          Details about land ownership, if provided for our “Map of Dreams”; 

• Your contact details and those of your business or destination of you provide them to be in the ‘Live’ listings.

•          Marketing preferences; and 

•          Technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access the website. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data under data protection law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of the website to calculate the percentage of users accessing a specific feature on our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. 

We will not collect or process Sensitive Personal Data (as defined in the Glossary) about you at any time. 

We will generally use your personal data to: 

•           Inform high-level strategy for the WildEast mission.

•          Provide you with any information or educational services that you request from us; 

•          Provide you with access to our newsletter; 

•          Personalise your experience on our website; 

•          Contact you by post, e-mail, telephone and via social media regarding any pledges made or other information that you may have requested from us; 

•          Update our “Map of Dreams” detailing the locations of all the land pledges made; 

Include your business or destination details in our Live section listings

•          Process any financial transactions (including collection of donations and management of any additional charges and fees); 

•          Generally administer our relationship with you; 

•          Respond to any enquiries that you submit to us; 

•          Send you information by post or e-mail about updates and news (see the “Marketing” section below for further details), including opportunities to get involved in any of our projects; 

•          Comply with our legal and regulatory obligations; 

•          Keep a record of your relationship with us; 

•          Prevent and detect fraud; 

•          Provide support (including investigating complaints); 

•          Train our staff and volunteers; 

•          Review and improve our operations; 

•          Use data analytics to improve our website, marketing, user experience and our charitable organisation in general; and 

•          Administer and protect the website and our charitable organisation (including troubleshooting, data analysis, testing and system maintenance and network security). 

Lawful basis for using your information 

In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a particular contract with you (for example, because you have requested our charitable educational services from us and we need to provide them). 

However, there are other lawful reasons that allow us to process your personal information, including where we have a “legitimate interest”. This means that the reason that we are processing information is because there is a legitimate interest for WildEast to process your information. 

Whenever we process your personal data on the basis of a “legitimate interest”, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is a disproportionate privacy impact on you. 

We will not publically host exact locations of pledges.

Marketing 

We may use your contact details to send you marketing communications if you are a donor and you have expressly given consent to receive those marketing communications. 

If you are not a donor and you have requested information from us or if you have signed up to our newsletter, we may also use your contact details to send you marketing communications unless you have specifically opted-out of receiving that marketing. 

•          We will not share your information for marketing purposes with any organisation or other entity outside of WildEast, unless we have your opt-in consent to do so. 

You can ask us or third parties to stop sending you marketing messages by contacting us at any time or clicking the “unsubscribe” button in the relevant e-mail. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any donation made to us. 

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

6. Disclosures of your personal data 

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 5 above. 

•          Any organisations that from time to time provide hosting services for our website. 

•          Any suppliers, sub-contractors and/or agents we work with to provide you with our services, including any educational services that you have requested from us. 

•          Any designers who are involved in uploading content to our website or otherwise modifying its design. 

•          Somerleyton Estate and entities associated with the Somerleyton Estate, for the purposes of providing administration and hosting services. 

•          Service and infrastructure providers who provide IT, security, website development, software, mapping, marketing, advertising and system administration services. 

•          Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related services. 

•          HM Revenue & Customs, law enforcement agencies, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

We do not and will not sell your personal data to any third party. 

7. International transfers 

Some of our external third party service providers or partners may be based outside the UK, in which case, their processing of your personal data may involve a transfer outside the UK. 

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented: 

•          We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK (such as EU or EFTA countries, New Zealand or Switzerland). 

•          Where we use certain service providers, we may use contracts incorporating standard data protection clauses recognised or issued in accordance with UK data protection law. which give personal data the same protection as it has under UK data protection law. 

Alternatively, we may transfer your personal data outside the UKwhere data protection law allows or requires us to do so. 

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the UK. 

8. Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff, volunteers, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

9. Data retention 

How long will you use my personal data for? 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Details of retention periods for different aspects of your personal data are available on request by contacting us using the details above. 

10. Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below for more information on your rights. If you wish to exercise any of the rights set out in the Glossary, please contact us. 

No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

11. Glossary 

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions. 

LAWFUL BASIS 

“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

YOUR LEGAL RIGHTS 

You have the right to: 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.