Clicks Help.com : Privacy Policy

In relation to the website Clicks Help.com(the “Site”)

Owner: CLICKS HELP B.V., trading as CLICKS HELPCompany registration number: xxxxxxx Registered Office: B Building, 400 Johan Huizingalaan, 1066 JS, Amsterdam, Netherlands

(“we/us”)

Customer services: hello@clickshelp.com

Postal address: Clicks Help, 142 Forest Hills, Newry, BT34 2FJ, United Kingdom

Clicks Help are committed to keeping your information secure and managing it in accordance with our legal responsibilities under privacy and data protection laws where we operate.

This Privacy Policy provides information about how we process personal information through the Site.

By visiting the Site or using any of our services, you agree to your personal information being used and disclosed in the manner set out in this Privacy Policy. For countries within the European Union, we will not collect personal information from you unless you have specifically agreed to us doing so (for example through your acceptance of this Privacy Policy or via an electronic tick-box or other similar measures) or unless we are otherwise permitted to by local privacy and data protection laws.

You do not have to provide your personal information to us, but if you do not provide certain information, we will only be able to provide limited services to you.

By submitting your information and subscribing to the services available on the Site, you consent to such use and transfer in this Privacy Policy.

The personal information that we collect

When you use the Site, as is the case with most websites, certain limited information (such as your browser type and IP address) will be collected by us automatically. We will also collect and store certain additional personal and private information about you(defined in the Data Protection Act 1998 as ‘personal data’) as follows:

YourClicks Help account

We will collect basic contact information about you to set up your account, so you can use the Service. This will include your name, address and email address. We will also ask you to register a username and password so you can gain secure access to your account in the future.

Alternatively you may authorise us to collect your basic personal details from a secure online source (e.g. Facebook) to which you have already provided this information.

If you choose to login via Facebook, we will obtain access to your public profile information and email address. We will use this information to allow you to login and populate our records about you. If you give us permission (via Facebook’s preference settings), we may also obtain access to your friend list; we will only use this to see if people on your friends list are also using the Site and as set out in How we use personal information below.

Making a donation through the Site

To enable us to process donations, we will collect basic payment information.

How we use personal information

We use the personal information collected from users for a number of purposes:

- providing notification emails to users

- to help us prevent fraud associated with online payments;

- improving the service we offer - for example you may be asked to complete one of our online user satisfaction surveys; participation in surveys is voluntary, and you are under no obligation to reply to any survey you might receive from us. Should you choose to do so, we will treat the information you provide with the same high standard of care as all other customer information.

We do not provide any personal information to a charity or not-for-profit or unless we have your permission to do so (or where we are required to do so by applicable law).

If you allow us to pass on your details to acharity or not-for-profit, you may receive further correspondence from them including emails telling you more about their cause and to thank you for your donation. If you do not allow us to pass on your details to them for these purposes they will not be able to contact you in this way. The fundraiser Charity,will be a data controller in respect of this information and any further correspondence you receive from them will not be governed by this Privacy Policy; it will be governed by their privacy policies (if applicable) and you may ask them to stop communicating with you by contacting them in accordance with the terms of their privacy policy (if applicable) and the relevant laws.

We will only use your information where we are authorised by law to do so (such as where we have obtained appropriate permissions from you, e.g. with tick boxes) and we will only use the information in accordance with this Privacy Policy, or where it is required or authorised by law.

Save as provided for in this Privacy Policy, Clicks Help will not sell, trade or rent Personal Information to third parties.

Providing information to others

Where you have indicated you would like to receive updates, we may send marketing in the form of email alerts and bulletins to tell you about developments in the services available through the Site, together with tips and news stories related to giving and fundraising for charities.

Where you have indicated that you would like to receive direct marketing communications from us, we will use your personal preferences which you have told us about, which we have derived from Cookiesand/or which we have inferred from your service usage (see our Security and Cookies Policy and see Analytics below) or market research .

If you subscribe to email alerts, bulletins or direct marketing communications from us and at any time you wish to stop receiving any of the above, you may do so by following the “unsubscribe” instructions included in our communication to cease electronic messages and you may change your preferences and cease receiving direct marketing from us through your account settings. If you require any assistance in doing so, you may contact us using the contact details below.

Communications from us

We work closely with a number of trusted partners with whom we need to share personal information to help us operate the Site. These include:

• banks and payment providers - to authorise and complete payment transactions;

• organisations within the payment card industry to help prevent online fraud;

• law enforcement bodies in order to comply with any legal obligation or court order and, where we are otherwise requested to provide information, we may provide it but only in accordance with applicable privacy and data protection laws;

We may also provide information to third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services and customer services (see Working with other service providers and group companies).

We will only share information with such organisations where we have your permission to do so in accordance with this Privacy Policy, or where we believe it is necessary for a legitimate reason connected with the services we offer.

You agree that we may disclose or share your personal information with such partners in order that we may operate the Clicks Help service.

Working with other service providers

For operational reasons, we transfer personal information to service providers who help us manage our systems and processes (such as card payment providers), and to deliver our services to users.

We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country.

In the event your personal information is transferred to a foreign jurisdiction (including outside of the European Economic Area), it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.

Your information may also be transferred to another company in the event of the transfer of our assets to a third party. In that event, we will endeavour to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected.

By submitting your information and subscribing to the services available on the Site, you consent to such use and transfer.

Keeping information secure

We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Updating your account and preferences

Please notify us of any changes to your personal information which you have provided to us. You can do this via updating your user preferences through your account settings or contacting us using the details below.

Keeping your records

We keep records for as long as required to operate the service in accordance with legal, tax and accounting requirements. Where your information is no longer required, we will ensure it is disposed of in a secure manner.

Analytics and social media plugins

We use analytics tools on the Site to provide the service you request, identify service issues to us, improve our services and to provide content tailored to users' personal preferences and profiles.

These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to the Site. We may disclose data, including personal information, to certain such third-party services providers in order to obtain such services.

Our provider is called Hubspot and the way their analytics service operates is set out in their privacy policies .

If you use buttons on the Site linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from the Site may be sent back to that other website and, depending on your privacy settings, may be privately or publically visible (for example to friends, followers or generally to anyone who has access to your profile page).

You may request further details on these other tools and third parties from us by using the contact details below. By submitting your Information and subscribing to the services available on our Site, you consent to such use and transfer.

Access rights

For the purposes of the Data Protection Act 1998, we are adata controller. You have the right to request copies of certain of your personal information within our custody and control and details of how we use that information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected. You have a right, in certain circumstances, to require us to stop processing your personal information. You also have a right, in certain circumstances, to request that we erase any links to or copy of your data.

In relation to all of these rights, please email or write to us at the address below. Please note that we may, where permitted under applicable law, charge a small administrative fee and/or request proof of identity. We will respond to your requests within all applicable timeframes.

In certain circumstances (for example where required or permitted by law), we might not be able to provide you with access to some of your personal information, but where appropriate we will notify you of the reasons for this.

Complaints Process

If you have a complaint about how we have handled your personal information, you may contact us using the details below and we will investigate your complaint.

Should we be unable to resolve your complaint in a manner you are satisfied with, you have the right to lodge a complaint withthe Information Commissioner’s Office.

Third party sites

This Privacy Policy only applies to the Site. If you land on the Site from other websites (or move to other sites from the Site), you should also read their separate privacy policies.

Updates

We keep this Privacy Policy under regular review and place updates on the Site from time to time. Please review this policy periodically for changes.

However, we will always notify you of material changes we make to this Privacy Policy and, where required under applicable privacy and data protection legislation, we will appropriately notify or give you the option to consent to changes to the PrivacyPolicy.

If you do not accept the amended Privacy Policy, please stop using the Site.

Contact

If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal information, please contact us via hello@clickshelp.com or write to Clicks Help, 142 Forest Hills, Newry, BT34 2FJ, United Kingdom.

Date: November 2017

Version: 1.0