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 13 - 5 April 2023