This Privacy Policy explains how Big Win Philanthropy, Inc., a Delaware not-for-profit corporation, and Big Win Philanthropy, a UK registered charity with registered charity number 1162036 (“Big Win”, “we”, “our” or “us”), as a data controller, may each collect, use, share and protect information that we obtain about you directly or indirectly in accordance with applicable data privacy laws.
Big Win Philanthropy is committed to protecting the privacy and security of your personal information.
Where you use our services, or your personal data is processed in connection with such services and we control the purpose for which such personal data is processed, Big Win Philanthropy will be the data controller of such information.
This Privacy Policy applies:
- to your inquiries submitted via the form on our website or emails or other electronic messages sent directly to our staff;
- to your use of any of our services where we are performing a data controller function;
- where you apply to us for a job or professional engagement;
- your supply of services to us where this involves any personal data; and/or
- to any personal information collected from third parties where we are the controller of such information.
This Privacy Policy applies to our website www.bigwin.org and any other website, mobile app or other online service created or hosted by us from time to time on which this Privacy Policy appears (together, our “Online Services“), through which we may collect certain data about you if, for example, you want to attend an event we are hosting or to subscribe to any publications or newsletters that we may periodically issue.
Our Online Services make use of cookies and similar technologies, as described in more detail in the Cookies Policy below.
This Privacy Policy does not apply to, and Big Win is not responsible for, any third-party websites which may be accessible through links from our website.
How We Collect Your Personal Data
“Personal data,” or personal information, means any information about you from which you can be identified. It does not include data where your data has been removed (anonymous data).
Where you use our Online Services, we will collect personal data directly from you.
We may also collect personal data from third parties such as your employer, regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third parties described the section titled “Disclosure of your information” below.
We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you information or other materials; when you sign up for an event; and when you respond to our communications or requests for information.
The information you provide may include current and historical personal data including your name, contact details, title, identification, date of birth, employment, positions held and enquiry/complaint details and information about the organization with which you are affiliated. We may also collect personal data about you during your dealings with us, including any contact we have with you in person, by telephone, email or online.
We may collect information from other sources, such as social media platforms, that share information about how you interact with our content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.
We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.
When you use our Online Services, including this website, we may collect the following:
- Information you provide by completing forms, registering for evens, or subscribing.
- Information you provide to us if you contact us.
- Details of visits made to our Online Services including, but not limited to, the volume of traffic received, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit) and the resources accessed.
- To the extent our Online Services require that you enter a password or other information in order to access them, we will collect such credentials.
If you apply for a job or professional engagement with Big Win, then you may need to provide additional information about your education, employment, and state of health. You will be provided a Privacy Policy in connection with same. We may also carry out screening checks (including reference, background, directorship, DBS, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.
We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers, referees and your current and previous employers. We may also gather additional information about you from publicly available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data, we may not be able to progress considering you for positions with us.
In some instances, personal data must be provided to us in order for us to legally or contractually perform services to you, including without limitation in connection with our Anti-Money Laundering and Know Your Customer processes.
Legal Basis for Usage Of Personal Data
Where we intend to use your personal data, we rely on the following legal grounds:
Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us, and where we respond to your requests and provide you with services in accordance with our terms and conditions (which are available on request) or other applicable terms of business agreed with you or with your employing organization.
Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data, which may include:
- for our own direct marketing or continued communication;
- the prevention of fraud;
- our own internal administrative purposes;
- personalization of the service(s) we provide to you;
- ensuring network and information security, including preventing unauthorized access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or
- reporting possible criminal acts or threats to public security to a competent authority.
Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, tax laws and other regulatory provisions applicable to Big Win Philanthropy or Big Win Philanthropy, Inc. as a corporation or a registered charity.
Consent: You may be asked to provide your consent in connection with certain services that we offer, or in respect of certain special categories of personal data such as your health or racial background for which we are legally obliged to gain your consent due to the sensitive nature of such information and the circumstances in which it is gathered or transferred. Where we are reliant upon your consent, you may withdraw this at any time by contacting us in accordance with the section titled “Further information” below, however please note that we will no longer be able to provide you with the products or services that rely on having your consent.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else's interests).
- Where it is needed in the public interest or for official purposes.
How We Use Your Personal Data
We use your information in order to provide you with, and improve, our services, for example:
- To provide you with Big Win’s services (as noted above) that you or your employing organization request.
- To respond to your enquiries.
- To carry out our obligations arising from any contracts entered into between you and us.
- To facilitate our internal business operations, including to fulfil our legal or regulatory requirements.
- To maintain and develop our relationship with you.
- For our business purposes, including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement.
- To maintain and update our records including our database of contacts.
- To provide you on an ongoing basis with information and services, including relevant marketing communications related to Big Win and our work, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us.
- To evaluate, recruit, and hire personnel.
- To measure the popularity and effectiveness of services in order to improve what we offer to you and other recipients.
- To allow you to use or access interactive features or secure areas of our online services, when you choose to do so.
- For research, planning, service development, security or risk management.
- In connection with travel or events.
- As we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protector your, our, or others’ rights.
We may not be able to do some or all of these things without your personal data.
If at any time we intend to change the purpose for which we hold your personal data, we will give you prior information of that new purpose so you are aware of this.
Disclosure of Your Information
We may exchange your personal data with trusted, vetted, third-party service providers contracted to Big Win where any of the following apply:
- You have consented to us sharing your personal data in this way.
- We deem reasonably necessary to provide you with the services that you have required at any particular time.
- Such sharing is provided for under contract.
- Such sharing is to law enforcement bodies or other government authority.
- We need to enforce or apply our terms and conditions, to which you have agreed (or other terms that have been agreed to apply to our relationship with you or your employing organization).
- It is necessary to protect the rights and interests, property, or safety of Big Win, our staff or grantees, or others.
- It is relevant in the circumstances to disclose the information to parties with whom we are conducting an event (such as jointly sponsored events, external venues, or caterers).
- Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analyzing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
- We use trusted, vetted third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, payroll, pension, marketing and security services.
- All, or most, of the assets of Big Win are merged with a third party, or we expand or we re-organize our business, in which case your personal data may form part of the transferred or merged assets.
- We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with a Court Order).
Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on Big Win’s behalf. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with our procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with applicable data privacy laws). If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
We own the database rights in the information collected via our Online Services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organization with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your express prior permission.
We may share information that does not reasonably identify you or your organization as permitted by applicable law.
International Transfers
Where you are submitting personal data from within the European Economic Area (“EEA”), such information may be transferred to countries outside the EEA.
By way of example, this may happen if your information is transferred from Big Win Philanthropy to Big Win Philanthropy, Inc. It may also happen if one or more of our third-party service providers with whom we share personal data in accordance with the section titled “Disclosure of your information” are located, or have their servers located, outside your country or the country from which the data were provided.
If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.
Retention of Your Data
We retain the information we collect no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.
Should you wish to review our retention policy then please contact us.
Security
We take steps to hold information securely in electronic or physical form.
Our information security policy is supported by a variety of processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All employees, officers or contractors of Big Win and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we only select third-party data storage providers that comply with appropriate information security industry standards.
Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.
If you communicate with us using a non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.
Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorized access, modification or disclosure.
You can help us to keep your information secure by ensuring that any user name or password in relation to our Online Services is kept strictly personal to you and not be made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.
Cookies Policy
Our website and Online Services use cookies and other similar technologies, for example, to distinguish you from other users when you browse our websites or use our online services and to allow us to improve our online services.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.
We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services. We use Google Analytics to collect data about the users of our Online Services in order to improve our offerings and the functionality and relevance of our Online Services.
Big Win’s website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to our website, you will have a better user experience.
Use of Cookies
Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on our website will be lost. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org which includes information on how to manage your settings for the major browser providers.
Your Rights
Under applicable data protection legislation, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate at data.privacy@bigwin.org.
Where you have consented to our processing of certain personal data, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our us. Please note that where you withdraw your consent we will no longer be able to provide you with the products or services that rely on having your consent. You can also exercise this right at any time by contacting us using the contact details at the end of this Privacy Policy.
You can request:
- access to the personal data we hold about you;
- corrections or updates to your details;
- the erasure of your personal data;
- the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format.
You also have the right to object to, or request the restriction of, our use of your personal data.
If you would like to exercise any of the rights set out in this section, please contact us using the details set out in the section titled “Further information” below. We may refuse to provide access where we have legitimate reasons for doing so under applicable data privacy laws, and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.
You may submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us.
If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.
Status of this Statement
Your provision of personal data to us or use of our Online Services constitutes your acceptance of the terms of this Privacy Policy.
As technologies and information governance practices develop, and data privacy laws (and surrounding guidance) evolve, we may need to revise this Privacy Policy. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.
We will post any Privacy Policy changes on this page and, if the changes are significant or may materially impact upon your rights, we will provide a more prominent notice or contact you by other means (including, for certain services, email notification of Privacy Policy changes).
Further Information
To find out more about Big Win Philanthropy, Inc. or Big Win Philanthropy please visit www.bigwin.org.
At your request, we can confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request the following information by contacting us using the details below:
- Identity and the contact details of the person or organization that has determined how and why to process your data.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Big Win or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
In order to verify the identity of those who make a request to us, we will accept the following forms of ID when information on your personal data is requested:
- Passport,
- Driver’s license, Birth certificate,
- Utility bill dated within the last 3 months.
Contact
If you have any questions, concerns or comments about this Privacy Policy, or want to submit a written complaint about how we handle your personal data, please contact us via any of the following means:
Mail: Big Win Philanthropy, 10 Queen Street Place, London EC4R 1BE, United Kingdom
Email: legal@bigwin.org
Shyam Radia, UK General Counsel and Deputy COO