1. INTRODUCTION

1.1 Welcome to The Howat Foundation’s privacy notice in relation to our website at https://www.howatfoundation.org (“Website”).  
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1.2 This privacy notice is issued on behalf of The Howat Foundation ("we", "us" or "our"), a charity (Registered in Scotland No SC040922) with our registered office at 7 Melville Terrace, Stirling, United Kingdom, FK8 2ND.
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1.3 This privacy notice will inform you about what data we collect from you, how we use it, circumstances where we may disclose this data to others and how we keep it secure. 
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1.4 We take the issue of security and data protection very seriously and strictly adhere to applicable data protection legislation. In accordance with the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act 2018 we are data controller of any personal data that you provide us.  
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1.5 Any questions relating to this policy and our privacy practices should be sent to The Howat Foundation’s Data Compliance Manager data@howatfoundation.org.
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2. HOW WE COLLECT INFORMATION FROM YOU

2.1 We collect and process your personal information in the following ways:
· you may give us information about you via our Website. This may include information you provide when you contact us via the Website, indicate your interest in our services or enter into a contract with us;
· you may give us information by corresponding with us by mail, text, e-mail, (or other form of electronic communication), telephone or in person;
· by visiting our Website we may automatically collect technical information which may form personal information; and
· we may receive personal data about you from various third parties and public sources including our Linkedin page at https://www.linkedin.com/company/the-howat-foundation/
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2.2 This Website is not intended for children and we do not knowingly collect data relating to children.
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2.3 It is important that you read this privacy notice 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 notice supplements the other notices and is not intended to override them.
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3. WHAT INFORMATION WE COLLECT

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).
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3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
· Identity Data: includes first name, maiden name, last name, username or similar identifier
· Contact Data: includes address, email address and telephone numbers;
· Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website; 
· Usage Data: includes information about how you use our Website
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4. WHY WE NEED THIS INFORMATION ABOUT YOU

4.1 We use the information we collect about you :
· to provide you with information, products and/or services you have requested;
· to help us with understanding more about how our Website is used; 
· to be able to send you communications that may be of interest to you, either electronically, by email, by text or otherwise; 
· to be able to respond to your query; and
· for all other purposes consistent with the proper performance of our operations.
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4.2 We will only use your personal data when we have legal grounds to do so. Most commonly, we will rely on one of the following legal bases:
· to enable us to perform the contract we have entered with you, including provision of the services;
· if required to comply with a legal or regulatory obligation;
· if necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
· if needed to protect your interests (or someone else's interests).
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4.3 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
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5. MARKETING

5.1 We do not currently and nor do we plan to send out newsletters or marketing emails. We are on Linkedin though, and you can follow our business updates at https://www.linkedin.com/company/the-howat-foundation
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6. COOKIE POLICY

This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.
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The cookies are in use to deliver Google Analytics service. These cookies are used to store information, such as what time your current visit occurred, whether you have been to the site before, and what site referred you to the web page.
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These cookies contain no personally identifiable information but they will use your computer’s IP address to know from where in the world you are accessing the Internet.
 
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Cookie Opt-out 
In order to provide website visitors with more choice on how data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to stop data being sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not affect usage of the website in any other way. A link to further information on the Google Analytics Opt-out Browser Add-on is provided below for your convenience.
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http://tools.google.com/dlpage/gaoptout?hl=None
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For more information on the usage of cookies by Google Analytics please see the Google website. A link to the privacy advice for this product is provided below for your convenience.
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http://www.google.com/analytics/learn/privacy.html
 
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Disabling Cookies
If you would like to restrict the use of cookies you can control this in your Internet browser. Links to advice on how to do this for the most popular Internet browsers are provided below for convenience and will be available for the Internet browser of your choice either online or via the software help (normally available via key F1).
Internet Explorer
Google Chrome
Mozilla Firefox
Apple Safari
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7. DATA SECURITY

7.1 Please be aware that the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk. 
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7.2 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 employees, 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. 
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7.3 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.
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8. SHARING OF YOUR INFORMATION

8.1 The information you provide to us will be treated by us as confidential.  We may also disclose your information to:
· our partners, suppliers and service providers for the purposes set out in the policy or for purposes approved by you.
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8.2 We require all third parties to respect the security of your personal data and to treat it in accordance with data protection legislation. 
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9. NO TRANSFERS OUTSIDE THE EEA

We will not transfer your personal data outside of the European Economic Area (EEA).
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10. HOW LONG WE WILL KEEP YOUR INFORMATION

10.1 We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you. 
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10.2 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.
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11. YOUR RIGHTS

11.1 Under Data Protection legislation, you have the following rights in connection with your personal data, which can be exercised in certain circumstances: 
· Right of access:  you can request a copy of the personal information we hold about you and check we are processing it lawfully;
· Right to rectification:you can request that any incomplete or inaccurate information we hold about you is corrected;
· Right to erasure:you can request that we delete your personal information where there is no good reason for us to continue to process it. You must provide valid reasoning for your request. This can be exercised in conjunction with the right to object (see below);
· Right to object:you can object to our processing of your personal information where we are processing on the basis of our 'legitimate interest' or that of a third party. We shall cease processing your personal data unless there are compelling and legitimate grounds for processing which override your interests;
· Right to restrict processing:you can request that we restrict our processing of your personal information. Information will be retained but not further processed;
· Right to data portability:where processing of personal data is carried out by automated means, you can request the transfer of your personal information to another party;
· Right to withdraw consent:where we are processing your personal data on the basis of consent, you have the right to withdraw your consent where we rely upon it as the lawful basis for processing; and
· Right to not be subject to decision making based on automated processing:you shall have the right to not be subject to decision making based solely on automated means including profiling.
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11.2 If you would like to exercise any of your rights above, please contact us at data@howatfoundation.org.
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11.3 You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. In the United Kingdom, the Information Commissioner's Office can be contacted via their website - https://ico.org.uk/
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12. THIRD PARTY WEBSITES

Because we want your experience of our Website to be as informative and useful as possible, we may provide links to websites operated by third parties ("Third Party Websites"). Please be aware that we do not control such Third Party Websites and that such Third Party Websites may send their own cookies to users, or otherwise collect data or solicit personal information. We assume no responsibility for the information gathering practices of Third Party Websites that you are able to access through our Website, and we encourage you to review each Third Party Website's privacy policy before disclosing any personally identifiable information.
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13. CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. 
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14. YOUR DUTY TO INFORM US

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.
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15. CONTACT US

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at data@howatfoundation.org.