Welcome to the Streeva Ltd privacy policy.
Streeva Ltd respects your privacy and is committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our website (regardless of where you visit it from) and in relation to our operation of the Swiftaid and Higher Rate Relief services and sets out details of your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
This privacy policy aims to give you information about how Streeva Ltd collects and processes your personal data through your use of this website and in connection with our operation of Swiftaid and Higher Rate Relief services.
Our website and services are 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 policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.
Streeva Ltd is the controller and is responsible for your personal data (referred to as “Streeva”, “Swiftaid”, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Streeva Ltd
Email address: uk.dp@streeva.com
Postal address: Carsize Barn, Carsize Lane, Leedstown, Hayle, TR27 5EX
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
We keep our privacy policy under regular review. The version number of this privacy policy and date on which it came into effect are displayed at the end of the privacy policy. Historic versions can be obtained by contacting 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.
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 of every website you visit.
Data Collection & Usage. When a contribution is made, we collect and process the following information:
This information is used solely for processing payments, providing receipts, and communicating with contributors regarding their payments. We do not sell, trade, or share contributor data with external parties for marketing purposes unless explicit consent is given.
Marketing Communications & Consent Swiftaid offers an option for contributors to opt in to receive marketing communications about our mission, progress, and product updates. If you choose to opt in:
Data Security & Retention Payment data is handled securely through third-party payment processors and is not stored directly by Swiftaid. Contributor details will be retained for financial record-keeping as required by UK law and will be deleted upon request where applicable.
Third-Party Payment Processing Payments are processed by Stripe, and users are subject to their respective privacy policy. Swiftaid is not responsible for data processing conducted by this external entity.
User Rights Contributors have the right to:
To exercise these rights, please contact us.
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).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
Identity Data means your first name, last name, username or similar identifier and title;
Contact Data means your address, email address and telephone number;
Payment Method Data means details of the payment method or device you use to make a donation, such as your payment card;
Donation Data means details of donations you have made together with associated Gift Aid declarations;
Technical Data means your 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, make donations or to log in to your Swiftaid/Higher Rate Relief account or access the Swiftaid API;
Usage Data means information about how you use our website, your Swiftaid account, Higher Rate Relief account and the Swiftaid API; and
Marketing and Communications Data means your preferences in receiving marketing from us and our third parties and your communication preferences.
Tax Data means information relating to your tax account, such as your total donations and pension contributions.
Authority Data means authorisation information given to us to act on your behalf.
We also create, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Donation Data and Usage Data to calculate the percentage of users donating via a particular platform or method. 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 do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We need to collect and store certain personal data in order that we can act as a donor intermediary and create and give Gift Aid declarations on your behalf when you make donations. If you do not provide us with this information, or if you subsequently object to our using it or request that we deleted it, we will be unable to act as your donor intermediary and you (and the charities your support) will not benefit from your Swiftaid account as intended.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Payment Method, Tax Data, and Marketing and Communications Data by filling in forms or by corresponding with us via our website, by post, or email. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website and use your Swiftaid account or the Swiftaid API, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties. We will receive personal data about you from various third parties as set out below:
If you register your Swiftaid account via a charity or fundraising platform that we work with rather than directly via our website, the charity or fundraising platform that you register through will share your Identity, Contact, Payment Method, Donation, Technical, Usage, and Marketing and Communications Data with us;
Each time you make a donation to a charity or via a fundraising platform or payment provider that we work with, that charity, fundraising platform or payment provider will share your Identity, Contact, Payment Method and Donation Data with us;
We may verify address details with providers such as the Royal Mail;
If you are an employee or representative of a charity, fundraising platform or payment provider that we work with, your employer may provide us with your Identity and Contact Data in order that we can communicate with you regarding Swiftaid or the use of the Swiftaid API; and
We will receive Technical Data from the following parties:
analytics providers such as Google; and
payment processing providers such as checkout.com
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
Where we need to comply with a legal obligation.
Where we perform contractual obligations for the Higher Rate Relief service.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending our e-newsletter to you. You have the right to withdraw consent to marketing at any time by contacting us or clicking the unsubscribe button you will find at the end of each e-newsletter email.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that 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 where more than one ground has been set out in the table below.
| Purpose / Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To create Swiftaid accounts | (a) Identity (b) Contact (c) Payment Method (d) Marketing and Communications | Necessary for legitimate interests (the effective provision of donor intermediary services for the benefit of Streeva Ltd and our stakeholders) |
| To communicate and manage our relationship with Swiftaid account holders, which will include: (a) sending a welcome email when an account is created; (b) providing notifications when Gift Aid declarations are created and given or scheduled to be created and given; (c) notifying changes to our terms or privacy policy; (d) contacting you to request reauthorisation to act as your donor intermediary; (e) responding to enquiries and support requests; (f) contacting you to request a Gift Aid declaration for donations where we are unable to create the declaration on your behalf; and (g) inviting you to participate in customer surveys | (a) Identity (b) Contact (c) Donation (d) Usage (e) Marketing and Communications | Necessary for legitimate interests (the effective provision of donor intermediary services for the benefit of Streeva Ltd and our stakeholders) |
| To match donation data from charities, fundraising platforms and payment providers against Swiftaid account holders | (a) Identity (b) Contact (c) Payment Method | Necessary for legitimate interests (the effective provision of donor intermediary services for the benefit of Streeva Ltd and our stakeholders) |
| To create Gift Aid declarations for donations made by Swiftaid account holders and send these to the relevant charity or fundraising platform | (a) Identity (b) Contact (c) Donation | Necessary for legitimate interests (the effective provision of donor intermediary services for the benefit of Streeva Ltd and our stakeholders) |
| To send Swiftaid account holders an annual statement confirming the total amount of Gift Aid claimed via the Swiftaid account in the previous year | (a) Identity (b) Contact (c) Donation (d) Usage | Compliance with legal obligation |
| To maintain a register of previous Swiftaid account holders who have withdrawn their authority for us to act as their donor intermediary or who have closed their Swiftaid account and screening against these registers to prevent us creating new accounts or Gift Aid declarations contrary to an individual's preferences | (a) Identity (b) Contact (c) Usage | Necessary for legitimate interests (to prevent the creation of Gift Aid declarations or creation of new Swiftaid accounts contrary to an individual’s wishes) |
| Retention of records to demonstrate: (a) collection of donor intermediary authorisations; (b) sending of annual statements; (d) revocation of donor intermediary authorisations and to comply with HMRC audit requirements | (a) Identity (b) Contact (c) Payment Method (d) Donation | Compliance with legal obligation |
| Retention of records of donations made to charities or via the fundraising platforms or payment providers we have partnered with | (a) Identity (b) Contact (c) Payment Method (d) Donation | Necessary for legitimate interests (to develop a database of donations that can be used to identify historical donations on which Gift Aid can be claimed as part of our planned future services to further enhance the benefits of Swiftaid for our benefit and the benefit of our stakeholders) |
| To save the progress of Higher Rate Relief form data allowing to continue entering data in the future. | (a) Identity (b) Contact (c) Tax (d) Payment (e) Marketing and Communications | Consent |
| To create Higher Rate Relief accounts. | (a) Identity (b) Contact (c) Tax (d) Payment (e) Marketing and Communications (f) Authority | Contract |
| To communicate and manage our relationship with Higher Rate Relief account holders, which will include: (a) Sending a welcome email when the account is created; (b) Providing a receipt for payment; (c) Providing a claim summary; (d) Notifying changes to our terms or privacy policy; (e) Sending prompts to continue the application/sign documents; (f) Sending a prompt email to claim the following tax year; (g) Responding to enquiries and support requests | (a) Identity (b) Contact (c) Tax (d) Usage (e) Marketing and Communications | Necessary for legitimate interests (the effective provision of Higher Rate Relief services for the benefit of Streeva Ltd and our stakeholders) |
| To take payment for the Higher Rate Relief service. | (a) Identity (b) Payment | Contract |
| Sending the authorising document for signature for Higher Rate Relief claiming. | (a) Identity (b) Contact (c) Authority | Contract |
| Submitting intermediary authorisation to HMRC for future Higher Rate Relief claim submission on your behalf. | (a) Identity (b) Contact (c) Authority | Contract |
| Submitting Higher Rate Relief claim to HMRC on your behalf. | (a) Identity (b) Contact (c) Tax | Contract |
| Checking the Higher Rate Relief claim progress with HMRC. | (a) Identity (b) Contact (c) Authority (d) Tax | Necessary for legitimate interests (the effective provision of Higher Rate Relief services for the benefit of Streeva Ltd and our stakeholders) |
| To communicate with employees and representatives of the charities, fundraising platforms and payment providers we work with, including in relation to: (a) the management of our relationship with, and the delivery of our services to, the organisation you represent; (b) your access to, or use of, the Swiftaid API; and (c) to respond to your queries and support requests. | (a) Identity (b) Contact (c) Technical (d) Usage | Necessary for our legitimate interests (for the running of our business, the maintenance of stakeholder relationships and policing of the use of the Swiftaid API) |
| To administer and protect our business and this website and the Swiftaid API (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | Necessary for our legitimate interests (for the running of our business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To deliver our e-newsletter to subscribers | (a) Identity (b) Contact (c) Marketing and Communications | Consent |
| To respond to data subject rights requests | (a) Identity (b) Contact (c) Payment Method (d) Donation (e) Technical (f) Usage (g) Marketing and Communications | Compliance with legal obligation |
| To use data analytics to improve our website, services, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
We do not undertake any marketing activity other than to send our e-newsletter to those who have subscribed for it (and we include an unsubscribe link at the end of each e-newsletter email to enable subscribers to easily opt-out). We never share your personal data with any third party for marketing purposes.
We do not use your personal data for automated decision making or the create profiles.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. You can also control whether or not we place non-essential cookies on your device by using the cookie consent manager tool on our website. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
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.
We may share your personal data with third parties as set out below:
Gift Aid declarations containing your Identity, Contact, and Donation Data will be shared with the charities you donate to and with HMRC as part of the Gift Aid process;
Authority Data, Tax Data and Identity information will be shared with HMRC as part of the Higher Rate Relief claims process;
Records containing your Identity, Contact, Payment Method, Usage, and Donation Data will be shared with HMRC for audit purposes;
External suppliers that provide IT and system administration services to us (as data processors) may be given access to our systems and the personal data that we hold about you if necessary to enable them to perform the relevant services for us;
Our professional advisers including lawyers, bankers, auditors and insurers may request, and be provided with, access to any personal data they require to provide us with consultancy, banking, legal, insurance and accounting services;
Regulators and other authorities such as the Charity Commission and Information Commissioner will be provided with access to personal data relevant to enquiries or investigations; and
If we choose to sell, transfer or merge parts of our business or our assets we may share your personal data with potential buyers or partners. If a change happens to our business, then the new owners may only use your personal data in the same way as set out in this privacy policy.
All third parties with which we share personal data are required to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party suppliers 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.
Some of our external suppliers 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:
Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
Ensuring that our suppliers sign specific contracts approved for use in the UK, which require them to give personal data the same protection it has in the 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.
We are ISO 27001 certified and 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.
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax, accounting, audit or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep some information about Swiftaid account holders (including Identity, Contact, Payment Method, Usage, and Donation Data) for six years from the end of the tax year in which they cease using their Swiftaid account for tax and audit purposes.
If you would like further information regarding our retention periods please contact us.
In some circumstances, you can ask us to delete your data; see Your legal rights below for further information.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
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 to continue 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 that 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 to 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 that 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; and
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 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.
Version 14 - 1 April 2025