PRIVACY POLICY

Introduction
Luminate is committed to protecting your personal information. We want your interactions with us to be safe and secure. This Privacy Policy relates to our use of any personal information we collect from you via our website (‘‘the Site’), email communications, online and social media platforms and live events. It also relates to our use of any personal information you provide to us by email, phone, letter or in person.

Please read the following carefully to understand our processes regarding your personal data and how we will treat it. We may revise and update this Privacy Policy from time to time, and we will indicate the date of last review at the bottom of this page. Please periodically review the Privacy Policy to check if you agree with the updates that we make. Your continued use of this Site indicates your agreement with this Policy and any subsequent changes.

Who we are
Luminate, Scotland’s creative ageing organisation.
Luminate is a Scottish Charitable Incorporated Organisation registered in Scotland (Registered No: SC044652).
Our registered office is at Causewayside House, First Floor, 160 Causewayside, Edinburgh EH9 1PR.

What personal information we collect from you and how we use it

• When you use our website, such as filling in one of our online forms or entering a competition
We will explain the purpose of collecting your personal information and how we will use it. We will not use the personal information collected on this website (e.g. when you submit an entry to a competition) for any purpose other than dealing with the service or information you have requested.
When you browse our website, we collect your IP address and anonymous information about your visit. Our website uses Cookies to gather usage data as you browse our site. Cookies are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For more information about our use of Cookies, please read below.

• When you sign up to our e-newsletters, which are distributed through a third party provider MailChimp
We would like to keep in touch with you to let you know about Luminate’s events and other creative ageing projects from across Scotland and the world, including services offered by other organisations. By submitting your personal information via a sign up form, you consent to receiving regular emails from Luminate. We collect your first name, last name and email address via our newsletter sign up form on the Site. You can expect on average between 1 to 2 emails every month, and you can unsubscribe from these communications at any time. We will email you because you have given explicit consent to receiving e-newsletters from us or we have legitimate interests in contacting you about our events and news.
We use MailChimp as our newsletter provider. Mailchimp is a US based company but has self-certified to the EU-U.S. Privacy Shield regimes, and lawfully transfers EU/EEA personal data to the U.S. in line with their Privacy Shield Certification. This means they store and use your data in compliance with the General Data Protection Regulations. For more information, please read Mailchimp’s Privacy Policy. [https://mailchimp.com/legal/privacy/]

• When you access our social media channels, including Twitter, Instagram, Vimeo, YouTube, Facebook, Flickr
We only receive personal information that you share with us voluntarily and that is compatible with your privacy settings. To find out more about how these social media companies process your personal information, we recommend that you read their privacy policies.

• When you contact us by phone, in person, by email or by post to make an enquiry
We will only collect personal information that is necessary to provide you with the services you have requested. We will always explain to you our purposes for collecting personal information at the point of collection and we will let you know if our purposes change.

• When you book a place or attend Luminate events and agree to receive marketing communications from us by giving consent
We will always explain to you our purposes for collecting personal information at the point of collection and we will let you know if our purposes change.
We will generally use this information to let you know event details, arrange attendance for you, and, if you agree, to send you related information.
We occasionally use a third party online event platform Eventbrite to manage bookings for our events. For more information, please read Eventbrite’s Privacy Policy. https://www.eventbrite.co.uk/support/articles/en_US/Troubleshooting/even…

What lawful basis do we have for processing your information
We collect personal information from you where we have a valid legal basis for doing so. We will make our purposes clear to you at the time of collecting personal information from you. We use the following lawful bases for collecting and storing your personal data:
• Consent
For the purposes of promotional and marketing activities, we rely on your consent to process your personal information. This means you have given us your explicit consent for this specific purpose. We will communicate this in a clear and transparent manner when collecting information from you.

• Contract
We rely on contract as a lawful basis for processing when we need the personal information to provide a contracted service with/for you. When you enter a competition or complete a survey, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us.

• Legitimate Interests
We also use personal information you provide for our legitimate interests purposes and only where our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms. Where we process your information on this basis (for example when we respond to your enquiry when you contact us), we do so after having given careful consideration to whether the same objective could be achieved through other means. We also consider whether processing (or not processing) might cause you harm or whether you would expect us to process your data, and whether you would consider it reasonable to do so.

• Legal Obligation
We use this lawful basis when it is necessary for us to comply with the law (for example to comply with child and vulnerable adult protection purposes or for other crime prevention purposes).

You can find out more about legal bases for processing on the Information Commissioner’s Office website https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio…

Who has access to your information
We are committed to protecting your personal data. Any details you give us will be held in accordance with the General Data Protection Regulations and subsequent legislation.
We’ll never share your personal information with others without your explicit permission. We use the third party event management and mailing platforms such as Eventbrite and Mailchimp who will share your contact details if you have consented for them to do this. We will never have access to any bank details you disclose to these sites.
We may share anonymised personal information about you with our funders and internally to better understand how visitors use our site and other online platforms.
We may transfer your personal information to a third party as part of any business restructuring or re-organisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.

International transfer of your information
We will seek to store your personal information in the UK. However, on some occasions, the information we collect may be transferred to online event management and newsletter mailing campaign platforms who may be based outside the UK. Where we allow a supplier to process your personal information outside the UK, we will ensure that we create and maintain appropriate safeguards with our suppliers so that your personal information is subject to the same standards and protections as apply to us when we are processing your personal information in the UK.
Where we work with USA-based suppliers, we ensure they are certified within the EU-US Privacy Shield framework, or can provide a comparable level of data security that meets the requirements of European data protection law.

How you can access, update or delete your information
The law gives you a number of rights to control what personal information is used by us and how it is used by us. You have a right to know what personal information we hold about you and to receive a copy of it, subject to some exemptions, by making a ‘subject access request’. We try to be as open as we can be in terms of giving people access to their personal information.

You can request that any personal information that is incomplete or inaccurate data that we hold about you is corrected, though we may need to verify the accuracy of the new data you provide to us. You have the right to object to Luminate using your information where we are relying on a legitimate interest (or those of a third party) and we would have to stop unless we have a sound overriding reason to continue. In specific circumstances, you have the right to have your personal data deleted, to put limits on what Luminate may do with it or to receive a copy in machine-readable form to take to another organisation. There are also specific legal rights relating to automated decision making but Luminate does not have any such processes. For more information on your rights under the GDPR, please see https://ico.org.uk/for-the-public/
If you want to exercise any of these rights, please contact us using the details below.

The accuracy of your information is important to us. You have the right to ask for a copy of the information Luminate hold about you at any time. You can also ask us to correct any inaccuracies in our records or ask to have your personal data deleted.
If you change email address, or any of the other information we hold is inaccurate or out of date, please email us at info@luminatescotland.org, phone us at 0131 668 8066 or write to us at Luminate, First Floor, 160 Causewayside, Edinburgh EH9 1PR.

Our e-newsletter communications include functions to opt-out at any time in the future. Communications will also contain information and links that will allow you to manage and update your account preferences.

How long we keep your information
We will retain personal information for as long as we need it for the purposes for which we collected it in line with our retention policy and to comply with obligatory legal requirements.

How to complain
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint. If you are not happy with our privacy policy or if any complaint then you have should tell us by emailing info@luminatescotland.org.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

Security
Luminate will always hold your information securely. To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards and procedures in line with the General Data Protection Regulation (GDPR). While we aim to keep our systems and communications protected against viruses and other harmful effects we cannot guarantee this.

Use of Cookies
Luminate’s website uses Cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.

Google Cookies
Luminate uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. We will never (and will not allow any third party to) use Google Analytics to track or collect any personally identifiable information of visitors to our Site. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. To find out more, please read Google’s Privacy Policy. https://policies.google.com/privacy

You can choose whether or not to allow the setting of cookies using the privacy settings of your browser. If you would like to opt out of being tracked by Google while visiting our website, go to http://tools.google.com/dlpage/gaoptout

Vimeo and YouTube Cookies
We embed videos from YouTube and Vimeo channels using privacy-enhanced settings. This may set cookies on your computer once you click on the video player. For more information, please read YouTube and Vimeo’s Privacy Policies: https://support.google.com/youtube/answer/7671399?p=privacy_guidelines&h…
https://vimeo.com/privacy

Are you 18 or Under?
If you are aged 18 or under‚ please get your parent/guardian’s permission before you provide personal information to us. Users without this consent are not allowed to provide us with personal information.

Use of photographs
When a photographer commissioned by Luminate is present at any of our events, we may use the resulting images on this Site, on social media and in other publicity materials online and in print. Permission to use these images in this way will be obtained from the subject (or carer/parent/guardian) at the time the photograph is taken. However, if subsequently you have a valid reason why an image should no longer be used, please contact us and we will remove it wherever possible.

Contact us
If you have any questions or concerns regarding this policy or the information we hold about you, please contact us at info@luminatescotland.org or 0131 668 8066. You can write to us at: Luminate, First Floor, Causewayside House, 160 Causewayside, Edinburgh, EH9 1PR.
This policy was last updated in May 2018.

Date of last review
This policy was last reviewed on 31 January 2020.