Purpose of this privacy notice

This privacy notice aims to give you information on how BAPS collects and processes your personal data through your use of this website and otherwise, including any data you may provide through this website when you register for an account, when you donate online or in person, and when you participate in our activities.

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. This is 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.

Controller

BAPS is the controller and responsible for your personal data (collectively referred to as BAPS, "we", "us" or "our" in this privacy notice).

A data protection officer (DPO) has been appointed, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights, please contact the DPO on the details set out below.

Contact details

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to address your concerns before you consider approaching the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

The data protection law in the UK will change on Friday 25 May 2018. Although this privacy policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests until May 2018 as we are still working towards getting our systems ready for these changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes if you are registered with us.

Third-party links & communication tools

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 notice of every website you visit.

When we communicate with you by email, we may use third party software or communication tools. We aim to ensure that your data is kept secure and confidential when we do so.

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 includes first name, last name, username or similar identifier, marital status, title, date of birth, gender and country of origin.
• Image Data includes instances where we may store your photographs and video shots for the purposes of print and digital records or promotional activity. If you physically visit us, CCTV images of you may be recorded but these are usually deleted within 1 month unless required for security or record keeping purposes.
• Contact Data includes home address, business address, email address and telephone numbers.
• Financial and Transaction Dataincludes donation amount and bank account (where you donate using direct debit mandate or standing orders). We never store your payment card details.
• 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 and services.
• Profile Data includes your username and password, donations made by you, your interests, preferences, feedback and survey responses.
• Education and Professional Dataincludes school and university education, professional qualifications, job title, industry and organisation you work for.
• Family Data includes children and teenagers details and relationship between household members.
• Usage Data includes information about how you use our website and services.
• Activities and Communications Data includes your preferences in receiving information from us and our third parties, as well as your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not (directly or indirectly) reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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. This data will be used in accordance with this privacy notice.

Other than as set out below, 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.

As part of our health awareness and screening campaigns, and in the event that we treat you medically, we may keep and retain certain health related information. In cases where our health screening activities are undertaken in conjunction with medical professionals or organisations, they will be responsible for recording and maintaining the relevant records and we will not retain such records.

If you fail to provide personal data

Where we need to collect personal data and you fail to provide that data when requested, we may not be able to provide the information or services you might otherwise normally expect to receive from us, and we may not be able to keep you updated with information about our activities, events and services. In certain cases, we may have to delete your personal data you have with us.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial and Family Data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you:
  • register for our events, services or activities;
  • create an account on our website;
  • subscribe to our service or publications;
  • request information to be sent to you;
  • enter in our fundraising activities, or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may 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.
• Third parties or publicly available sources. We may receive or obtain personal data about you from various third parties and public sources; for example, Identity and Contact Data from publicly availably sources such as Companies House, libraries and the Electoral Register based inside the European Union.

Most commonly, we will use your personal data in the following circumstances:

• Where we need to keep you informed about our Satsang activities, services, news and events.
• Where we need to process a transaction we have entered into with you, e.g. to process a donation you may have made, or register you for a free or paid for event or activity.
• To perform a contract we are about to enter into or have entered into with you (e.g. to buy items or services).
• 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 (see further below).
• Where we need to comply with relevant legal or regulatory obligations.

One of the lawful bases on which data can be lawfully processed is for the legitimate interests. We are of the view that, in most cases, it is in our, your and the community’s legitimate interest to process your data in the way that we do, including when we notify you of our Satsang related news, events and activities. Most of our data processing is carried out with a view to fulfilling BAPS’ objective and promoting our activities and services, which we believe you are equally interested in. The data processing we are involved in is targeted and proportional to meet this objective, and you would reasonably expect us to process the data in the ways we do.

We do not generally rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and also which legal bases we rely on to do so. We have also identified what the legitimate interests are where appropriate.

Please kindly 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.

Marketing

We would not describe the Satsang news and events information we provide to you as ‘marketing’. We want to keep you updated about our Satsang events, services, news and activities and we believe that in most cases you are pleased and indeed keen to hear from us.

We may from time to time contact you about sponsorship or donation opportunities e.g. Sponsor a Thali at Diwali time. We believe it is in our legitimate interests do so and we will generally contact you by email where you have specifically consented or by post.

Sharing Data with third parties

We do not intent to share your personal data with any company outside of BAPS, except as set out elsewhere in this privacy policy.

Opting out

We strive to provide you with choices regarding personal data use.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking the relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

We have established myBAPS, an on-line portal for all satsangi devotees located within United Kingdom and Europe, where you can view and make decisions about your data and communication preferences.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that some parts of this website may become inaccessible or not function properly if you disable or refuse cookies.

Change of purpose

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. Please feel free to contact us should you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.

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.

We may share your personal data within the BAPS Global Group. This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the United States of America(referred to hereafter as "USA"), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the USA. For further details, see European Commission: EU-US Privacy Shield.

Please contact us should you require further information on the specific mechanism used by us when transferring your personal data out of the European Economic Area(EEA).

Appropriate security measures are in place 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, volunteers, 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.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting the Data Protection Officer.

We are required by law to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for taxation purposes.

In some circumstances you can ask us to delete your data. Please see below for further information.

In some circumstances 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. Please click on the links below to find out more about these rights.

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

You may also be able to exercise some of these rights yourself using the myBAPSportal.

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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

LAWFUL BASIS

Legitimate Interest means the interest of BAPS, BAPS devotees, and the community as a whole in conducting and managing our affairs, events and activities in such a manner as to enable us to meet our charitable objectives, and to give you the best service and the most enjoyable experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

BAPS Global Group

All companies, trusts and entities in India, the USA and elsewhere with which BAPS is associated.

Internal Third Parties

BAPS branches in London and its surrounding areas, other cities and towns in UK and Europe who are acting as joint controllers or processors.

External Third Parties

• Service providers acting as processors based in UK and Europe who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, insurers and other consultants.
• Health professionals and organisations including doctors, pharmacists, nurses, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and the European Union, who require reporting of processing activities in certain circumstances.