INTRODUCTION

 

Welcome to Charity Challenge’s Privacy Policy.

Challenges Un Limited (Trading as Charity Challenge) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.

Please also refer to the Glossary that we have set out at the end of the Policy if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.

 

1.    IMPORTANT INFORMATION AND WHO WE ARE

2.    THE DATA WE COLLECT ABOUT YOU

3.    HOW YOUR PERSONAL DATA IS COLLECTED

4.    HOW WE USE YOUR PERSONAL DATA

5.    HOW WE DISCLOSE YOUR PERSONAL DATA

6.    WHEN WE TRANSER YOUR DATA OVERSEAS

7.    HOW WE SECURE YOUR DATA

8.    HOW LONG WE RETAIN YOUR DATA FOR

9.    YOUR LEGAL RIGHTS

10.    GLOSSARY

 

1.    IMPORTANT INFORMATION AND WHO WE ARE

 

PURPOSE OF THIS PRIVACY NOTICE: This privacy notice aims to give you information on how Charity Challenge collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you book onto a challenge, purchase any services, sign up to our newsletter, take part in a competition and so on.

 

This website is not intended for children under 16 and the only circumstances in which we collect data relating to children, is where you make a challenge booking and you have a child under 18 in your party, for which you will provide the relevant personal data (name, passport, dietary requirements, medical details and so on).

 

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.

 

CONTROLLER: Challenges Un Limited is the controller and responsible for your personal data (collectively referred to as "CUL", "we", "us" or "our" in this privacy notice). We have appointed a data protection officer (DPO) 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 legal rights, please contact the DPO using the details set out below.

 

Contact details
Full name of legal entity:    Challenges Un Limited t/a Charity Challenge
Name of DPO:                       Simon Albert
Email address:                      info@charitychallenge.com
Postal address:                     49 Friern Barnet Lane, London, N11 3LL, England
Telephone number:             +44 (0) 20 8346 0500

 

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 (ico.org.uk) or the local data protection regulator when you live outside of the UK. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or your local data protection regulator, so please contact us in the first instance.

 

Changes to the privacy notice and your duty to inform us of changes: This version was last updated on 19 Jan 2022 and 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 any of the details you provide to us should change, during your relationship with us.

 

Third-party links: 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.

 

2.    THE DATA WE COLLECT ABOUT YOU

 

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 follows:

 

(A)    Identity Data: This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

(B)    Contact Data: This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.

(C)    Financial Data: This include data relating to your methods of payment, such as your payment card details.

(D)    Transaction Data: This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

(E)    Technical Data: This includes more technical data that we may obtain when you make use of our website, such as 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.

(F)    Profile Data: This includes the data that we receive when you create a profile on our website and make use of that data, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

(G)    Usage Data: This includes information about how you use our website, products and services.

(H)    Marketing and Communications Data: This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also 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 will treat the combined data as personal data which will be used in accordance with this privacy notice.

 

Special Categories of Personal Data: We collect the following special categories of personal data about you:

•    dietary requirements which may disclose your religious or philosophical beliefs;
•    health, by way of your medical history;

 

We collect and process the above data only where it is strictly necessary to do so to deliver the challenge that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.

 

You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the challenge that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.  

 

If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the challenge you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellations in the CANCELLATIONS BY YOU clause of our Booking Terms and Conditions will become payable.

 

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

In other words, where we require details from you to provide you with your chosen challenge, if you do not provide us with the necessary details then we will not be able to provide the challenge you have booked or are attempting to book.  

In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.

 

3.    HOW YOUR PERSONAL DATA IS COLLECTED?

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

 

(A)    Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
•    make a challenge booking;
•    create an account on our website;
•    subscribe to our newsletter or other publications;
•    request marketing to be sent to you;
•    enter a competition, promotion or survey; or
•    give us some feedback.

 

(B)    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. Please see our cookie policy for further details.

 

(C)    Third parties

We may receive personal data about you from various third parties as set out below:

(i)    Technical Data from analytics providers such as Google based both inside and outside the EU;
(ii)    Identity and Contact Data from Charities based both inside and outside the EU that refer challenge participants to us (where you have made an enquiry via that Charity).
(iii)    Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SAGE PAY based inside the EU.

 

4.    HOW WE USE YOUR PERSONAL DATA

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 we need to perform the contract, we are about to enter into or have entered into with you.
•    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.
•    Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on express consent as a legal basis for processing your personal data other than in relation to sending 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 or unsubscribing from our email communications.

 

Purposes for which we will use your personal data: 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

Retention period

To register you as a new customer.

(a) Identity;
(b) Contact.

Performance of a contract with you.

6 years for Identity and Contact data

To process and deliver your booking including:

(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.
    (a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and Communications.

(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).

6 years for Identity and Contact data,
7 years for Financial and Transactional data, 4 years for Marketing communications

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy;
(b) Asking you to leave a review or take a survey.
    (a) Identity;
(b) Contact;
(c) Profile;
(d) Marketing and Communications.

(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

4 years

To enable you to partake in a prize draw, competition or complete a survey.

(a) Identity;
(b) Contact;
(c) Profile;
(d) Usage;
(e) Marketing and Communications.

(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

4 years

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity;
(b) Contact;
(c) Technical.

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.

4 years

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

4 years

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

4 years

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

4 years

 

Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  We have set out below the various ways that we endeavour to allow you to exert such choices.

 

Promotional offers from us: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

 

Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us because of a purchase of a challenge or other such transaction.

 

Cookies: 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.

 

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, and as otherwise required or permitted at law. 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, that is not otherwise required or permitted at law, 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.

 

5.    DISCLOSURES OF YOUR PERSONAL DATA

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.

 

(A)    Internal Third Parties as set out in the Glossary.

(B)    External Third Parties as set out in the Glossary.

(C)    Specific third parties, such as JUST CHALLENGE.

(D)    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 notice.

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.

Group Bookings: Individuals taking part in the same Challenge may be booked on a group booking basis when a Challenge requires flight reservations. Due to certain airline booking systems, those on the same booking may have visibility to each other's personal data when retrieving  flight details on the provider's platform (and through flight booking correspondence sent by the provider). Such personal data may include name, dietary requirements and/or other information required by the airline to confirm a flight booking.  If you have concerns regarding this, please contact us. 

 

6.    INTERNATIONAL TRANSFERS

As we are UK based and our challenges take place all over the world, many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Where you have made a challenge booking which is located or otherwise due to be fulfilled outside the UK, we are required and are permitted to transfer your personal data to the supplier of the challenge services that you have purchased, outside the UK to fulfil the contract we have with you.

Whenever we transfer your personal data outside 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 by the European Commission. For further details, please contact us.

•  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.

•  For residents of Canada, personal data may be shared, accessed, stored or otherwise processed outside of Canada by those parties described in section 6 above in jurisdictions that have data protection laws (privacy laws) different than those in Canada, including access rights to personal data by law enforcement and government authorities in such other jurisdictions.

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

 

7.    DATA SECURITY

 

We have put in place appropriate security measures designed 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.

 

8.    DATA RETENTION

 

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 listed in the table above. In addition to the above, by law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Request erasure 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.

 

9.    YOUR LEGAL RIGHTS

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:

 

(A)    Request access to your personal data.
(B)    Request correction of your personal data.
(C)    Request erasure of your personal data.
(D)    Object to processing of your personal data.
(E)    Request restriction of processing your personal data.
(F)    Request transfer of your personal data.
(G)    Right to withdraw consent.

 

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

 

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, or as otherwise required by applicable laws. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

 

10.    GLOSSARY

 

LAWFUL BASIS

•    Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure 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.

•    Performance of Contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

•    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

•    External Third Parties

i.    Suppliers of travel services acting as processors based in any of the challenge destinations, who provide the travel services that make up any booking of travel services that you make with us.

ii.    Service providers acting as processors based in the UK who provide IT and system administration services.

iii.    Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the UK who provide consultancy, banking, legal, insurance and accounting services.

iv.    HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

v.    Charities or Corporates acting as processors or joint controllers and based both in and outside the UK for whom you are raising funds, or who are promoting your challenge, as a consequence of your challenge booking.

 

YOUR LEGAL RIGHTS

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:

(a)    if you want us to establish the data's accuracy;
(b)    where our use of the data is unlawful, but you do not want us to erase it;
(c)    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; or
(d)    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.

 

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ATOL protected

We hold an Air Travel Organiser's Licence granted by the Civil Aviation Authority. Our ATOL number is 6546. Many of the flight-inclusive challenges on this website are financially protected by the ATOL scheme. But ATOL protection does not apply to all holiday and travel services listed on this website. This ATOL protection only covers challenges that include flights booked by Charity Challenge and that originate in the UK. Please ask us to confirm what protection may apply to your booking. If you do not receive an ATOL Certificate then the booking will not be ATOL protected. If you do receive an ATOL Certificate but all the parts of your trip are not listed on it, those parts will not be ATOL protected. Please see our booking conditions for information or for more information about financial protection and the ATOL Certificate go to: www.atol.org.uk/ATOLcertificate

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