Privacy Policy

Last updated: 22nd January 2024

1. What does this policy cover?

This Privacy Policy sets out how GiveCircle Ltd (“GiveCircle”, “us”, “we”) collects and uses your personal data in the following scenarios:

  • When you access the “Website”. The “Website” refers to any web page hosted on the following domains, including any subdomains: givecircle.com and ndacs-givecircle.com. We may add additional domains to this list at any time;
  • When you participate in the GiveCircle Lottery (the “Lottery”);
  • When you make a donation via the GiveCircle platform;
  • When you contact us;

Personal data means any information from which you could be identified. It doesn’t include data where your identity has been anonymised or removed.

GiveCircle is registered in England and Wales, company number 04395570. Our registered address is The Stables, St Georges Terrace, Newcastle, NE2 2HB.

This website is not for children and we will never knowingly collect data relating to children.

2. What information do we collect?

We collect and process personal data about you when you interact with us or our Website. This includes:

  • Where you enter the GiveCircle Lottery or make a donation via the GiveCircle platform:
    • name;
    • mobile phone number;
    • payment details (this may include bank details depending on your chosen payment method);
  • Where you have already entered the GiveCircle Lottery or made a donation and choose to provide additional information:
    • contact information, such as postal address and email address;
    • personal information, such as date of birth, title and gender;
  • Where you win a prize in the GiveCircle Lottery:
    • contact information, such as postal address;
    • any personal information necessary to grant the prize;
    • photographs, video recordings and information when you choose to provide that information;
  • Where you contact us to self-exclude from the GiveCircle Lottery:
    • name;
    • contact information, such as mobile phone number, postal address and email address;
  • Where you interact with our Website or communications:
    • your marketing preferences, including any consents you have given to us or charity partners;
    • information related to the browser or device you use to access our Website;
  • Where you voluntarily participate in feedback or market research activities:
    • survey information such as shopping habits, age, gender, income, or other survey data you may choose to provide us if you participate;

3. How do we use this information, and what is the legal basis for this use?

We detail below the purposes for which we use this information, how we use it and who we share it with, and the legal basis for that use.

At a high level, personal data may be shared with third party service providers, who will process it on behalf of GiveCircle for various operational purposes (such as website hosting, maintenance, payment processing services, communication services, and the like). We may also share information with third parties to provide and personalise our communications about the Website and to measure the effectiveness of those communications.

More specifically, we process and share personal data related to the Website for the following purposes and legal bases:

  • To fulfil a contract or take steps linked to a contract.
    • Where you enter the GiveCircle Lottery, we will use your information:
      • to verify your identity;
      • to take payments;
      • to communicate with you, including sending you automated service messages;
      • to provide customer service;
      • to draw the winners; and
      • to arrange the delivery or other provision of prizes for the winners of the draw.
    • Where you make a donation via GiveCircle, we will use your information:
      • to verify your identity;
      • to take payments;
      • to communicate with you, including sending you automated service messages;
      • to provide customer service;
    • Where you have self-excluded from the GiveCircle Lottery, we will use your information:
      • to verify your identity;
      • to ensure no attempted entries are processed; 
      • to ensure no marketing communications are sent to you;
      • to provide customer service;
  • As required by GiveCircle to conduct our business and pursue our legitimate interests, we will use your information:
    • to provide products and services you have requested;
    • to help us monitor, improve, and protect our products, content, services, and the Website, both online and offline;
    • to investigate and respond to any complaints received from you or from others, about the Website or our products or services;
    • where you have use our products or services, to send you direct marketing (e.g. email, text message, phone call, postal communications) to promote similar products and services. You can opt out of this marketing (i) at the time of the collection of your details, (ii) by using the links within the marketing communications or (iii) by contacting us;
    • to personalise the Website, our products or services for you;
    • to provide targeted advertising on the Website, selected partner sites and social networks;
    • to process payment details, payments and check the validity of the payment details you submit in order to prevent fraud;
    • to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
    • to provide the prize to winners;
    • in connection with legal claims, compliance, regulatory, and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
    • to invite individuals to provide feedback and take part in market research; and
    • in connection with those cookies and similar technologies that are strictly necessary to make the Website function (which cookies we place in accordance with our Cookies Policy and the information provided to you when those technologies are used).
  • Where you have given consent to a charity partner, we will use your information:
    • to send direct marketing, where a charity partner has requested us to send direct marketing on its behalf;
  • For purposes which are required by law, we may use your information:
    • in response to requests from government or law enforcement authorities conducting an investigation or courts;
    • in response to requests from a regulatory body requiring information as part of a report or investigation.

4. Who do we share your personal information with?

We may share your personal data with the parties set out below for the purposes set out in the table above.

The following third parties:

  • Charities (that are controllers in their own right with their own privacy policies that you should check) that you are supporting by playing the lottery of making a donation, IT service providers, our professional advisors (e.g. lawyers, banks, auditors, insurers etc.), HM Revenue Customs, regulatory bodies and other authorities acting as joint controllers based in the UK who require reporting of processing activities in certain circumstances (e.g. the Charity Commission, the Gambling Commission etc.)
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

International data transfers

Some of our external third parties (e.g Google Analytics) are based outside the UK so their processing of your personal data will involve a transfer of data 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 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. For further details, please contact us or visit the Information Commissioner’s website at ico.org.uk.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details, please contact us or visit the Information Commissioner’s website at ico.org.uk.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Third party websites

Please note that our 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 of every website you visit.

Please note that if you post a comment to our Website or any social media pages managed by us, the information that you choose to post, including any personal data that you choose to post, may be available generally to the public.

5. What rights do you have?

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • 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.
  • 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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 could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. For example, you may opt-out of emails and/or text messages at any time.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

6. How long will you retain my personal data for?

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, and for 6 years after this.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

7. Changes to this Policy

We keep this Privacy Policy under regular review and any relevant changes or updates will be posted on this page and, where deemed appropriate, communicated to you via email, SMS or letter depending on which contact details we hold for you. The new/updated policy may be displayed on screen when using this website and you may be required to read and accept the changes to continue using the website.