PRIVACY Policy OF TOgETHER GIBRALTAR
This is the Privacy Policy of TOGETHER GIBRALTAR. Please read it carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information.
This Privacy Policy is designed to give you the information which the law says you are entitled to in respect of your personal information. It also shows you our commitment to transparency in the way that we deal with your information and explains your rights and how to contact us or the supervisory authority in the event you have a complaint.
When we collect or use personal information we are subject to the General Data Protection Regulation and our Data Protection Act 2004 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our, the party: Together Gibraltar is a political party in Gibraltar incorporated as a company limited by guarantee with incorporation number 118114.
Personal information: Any information relating to an identified or identifiable individual
Special category personal information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic and biometric data, Data concerning health, sex life or sexual orientation
Personal information we collect about you
We may collect and use the following personal information about you:
name and contact information, including email and residential address and telephone number
date of birth
gender information
communication preferences
direct marketing preferences
information about your financial transactions with us
family details
political opinions and topics you are interested in
voting intentions
religious or other beliefs
issues that you raise with us
How your personal information is collected
We collect most of this personal information directly from you, for example:
In person, when you speak to one of our elected representatives, our representatives or volunteers
Through a telephone call, either where we call you or you call us
On paper, such as if you return a printed survey or a reply slip on a leaflet
Digitally, such as if you fill in a form on our website or interact with the party online via our website, social media platforms or by email. This may include additional information we may collect from you such as:
your IP address
your device, browser or operating system
details of the links that you access and the content you view
your username or social media handle
your responses to surveys, competitions and events
any information you share when using third party sites (for example sending a tweet or liking on Facebook)
from cookies on our website—for more information on our use of cookies
When you offer or ask about volunteering, or take part in party activities
When you enter into a transaction with the party, such as donating, joining, purchasing a product or paying for an event
Indirectly for example from third party sources, for example:
from public records or sources, including the electoral register
on social media platforms, where you have made the information public, or you have made the information available in a social media forum run by the party.
CCTV if you visit the headquarters of Together Gibraltar
We may also collect personal information about you from other public sources such as the Land Registry, Companies House or other commercially available sources where we have a legal basis to do so. This will be mainly for our political activities. We may also check suitability for and identify potential donors to the party.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so. Together Gibraltar is a political party in Gibraltar and our work is designed to promote our values and to engage citizens in the democratic process. Our work is therefore considered to be of substantial public interest and is one of the lawful bases for processing personal information about you.
In addition we may also rely on any of the following grounds when processing your information:
to comply with our legal and regulatory obligations;
to fulfil a contract with you or to take steps at your request before doing so;
for our legitimate interests; or
where you have given consent.
As a political party, we are also allowed to process “special categories of personal information” for example information about your political opinions or voting intentions because our political activities such as campaigning, fund raising, political surveys and case-work are deemed to be of substantial public interest.
However you have the right to give us notice in writing that you object to our processing of special categories of personal information.
We use your information in order to further our political objectives, share it with our elected representatives and to contact you. We may also combine different types of information (also known a as “profiling”).
We may do this in order to:
contact you and canvass for your political support
let you know what our policies are, campaigns, events and how you can get involved with our party
understand what is important to you and what your views are
decide what messages and information we send you or show you on social media
estimate how you might vote in an election or referendum
analyse the results of any surveys you have participated in
respond to any queries you have raised with us
process your application for membership and administering your membership
carrying out fundraising activities and processing donations
managing our website and social media platforms
sending you electronic messages about us
Where we do combine your personal information, we will do this in a way which does not significantly affect you or create any legal effects.
Promotional communications
When you register online or as a member, volunteer or fill in a form, we may use your contact details to provide you with promotional communications about the party in electronic form in accordance with this Privacy Policy.
As a political party we also have a legitimate interest in generally processing your personal information for our activities (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always respect the Opt-out Register which is maintained by the Gibraltar Regulatory Authority with regards to telephone calls unless you have chosen to receive calls from us from a particular number.
We will always treat your personal information with the utmost respect and never share it with other organisations for their marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
contacting us at contact@togethergibraltar.com
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
Who we share your personal information with
We may share personal information with third parties who assist us in providing a service to you and who assist us to promote our activities by providing you with advertisements, online content and information about our politicians, campaigns and policies which you may be interested in. We also share personal information with third parties approved by you, eg social media sites you choose to link to or third party payment providers.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
Where your personal information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention time limits apply for different types of personal information and while we do not use definitive time limits for data retention, we do review the data we hold periodically to see whether we need to keep it, taking a number of factors into account such as:
the purposes for which the information was provided or obtained
our legitimate interests for keeping the information for example to respond to questions or complaints
any legal or regulatory record keeping requirements
whether holding on to your information infringes your rights
Transferring your personal information out of the EEA
To deliver our services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA). These transfers are subject to special rules under European and Gibraltar data protection law.
We will, however, ensure the transfer complies with data protection law and all personal information will be as secure as it would be inside the EEA. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission or if the transfer is to the USA, that it complies with the EU-US Privacy Shield.
If you would like further information please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your personal information (the right of access)
Rectification: The right to require us to correct any mistakes in your personal information
To be forgotten: The right to require us to delete your personal information—in certain situations
Restriction of processing: The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object: The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of the GRA for guidance.
If you would like to exercise any of those rights, please email, call or write to us - see below: ‘How to contact us’.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Gibraltar is the Gibraltar Regulatory Authority (GRA) who may be contacted at info@gra.gi or telephone: 20074636.
Changes to this privacy policy
This privacy notice was published on 28th November 2018.
We may change this privacy notice from time to time—when we do we will inform you via our website and or by email.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Name: Together Gibraltar Ltd
Address: First Floor 230/6 Main Street, Gibraltar
Email: contact@togethergibraltar.com
Telephone: 20042694
Do you need extra help?
If you would like this notice in another format (for example in large print) please contact us (see ‘How to contact us’ above).