Smile International

Please read our privacy policy.

Who we are

Smile International is a charity registered in England and Wales (number 1163423). We are also a charitable company limited by guarantee (number 09626673) and our registered address is PO Box 171, Bourne, PE10 1FB.

Smile International is passionate about helping to relieve suffering and poverty around the world through our FEED programmes – Feeding, Educating, Empowering and Developing.

We are dedicated to giving hope to those in need and providing people with an opportunity to develop emotionally, physically, socially and spiritually.

Developing a better understanding of our supporters through your personal data allows us to make better decisions, fundraise more efficiently and, ultimately, helps us to reach our goals through our FEED programmes – a dream to receive a meal at school, made possible through our Feeding programmes; a hope that a parent’s child goes to school so they learn to read and write, which can be achieved through our Educating programmes; a dream to learn a new life-changing skill, which is provided through our Empowering programmes, and a hope for easy access to water in a local village, which is fulfilled through our Developing programmes.

We are committed to protecting your personal information and being transparent about what we do with it, irrespective of how you interact with us, e.g. whether you want to learn more about what we do, donate, order online, want information or want to work with us.

This privacy policy describes how Smile International collects, uses and stores personal information and what it means for you. The terms of this policy may change, so please check it from time to time. For the purposes of this policy, ‘us’, ‘we’ and ‘our’ refer to Smile International.

If you have any queries about this privacy policy, please contact our Data Protection Officer by post at:

Data Protection Officer, Smile International, PO Box 171, Bourne, PE10 1FB

Or email our Data Protection Officer at:

[email protected]

Privacy policy

This privacy policy sets out how we use and protect any information that you give us when you use this website.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from the 25th of May, 2018.

Why we hold and process your information

We will provide a clear explanation of the purpose for which personal information is collected and processed. By providing us with your personal data, you consent to the collection and use of this information in accordance with the purposes described in this privacy policy.

We may hold and process your personal data for several reasons:

• To keep a record of donations made to us and actions taken by our supporters, and our communications with them
• To claim Gift Aid on donations, where applicable
• To administer our child and beneficiary sponsorship programme
• To send our supporters information about our projects, fundraising activities, appeals and prayer needs where we have their consent or are otherwise allowed to do so.  Please see our section on legitimate interests. We will only send you marketing information by post, email, phone or SMS, if you have given us specific consent or legitimate interests.
• To fulfil contractual obligations entered into with our suppliers, volunteers, staff and supporters e.g. online gifts and child sponsorship
• We may process your personal information where we reasonably think that may be a risk of serious harm or abuse to you or someone else
• To record fundraising activities and actions by our supporters. We will only send you marketing information by post, email, phone or SMS, if you have given us specific consent or legitimate interests
• To record and deal with a compliment or complaint, record what our volunteers have done for us, and for other essential internal record keeping purposes
• To gather information if we invite you to participate in surveys to help us improve our website, fundraising and strategic development. Participation is always voluntary, and no individuals will be identified as a result of this research, unless you give consent for us to publish your feedback
• To ensure we do not send unwanted information or literature to our supporters or members of the public who have informed us they do not wish to be contacted

We may contact you by post, email or telephone where we have a legitimate interest to do so. For example, where you have previously donated, or set up a child or beneficiary sponsorship.  We may continue to send you information about the work your donation is making possible or other work we may wish to do. If you have previously asked us not to contact you in this way, we will continue to respect your contact preferences. You can change your preferences at any time or object to us processing your data by contacting us by post or email, as provided in this privacy policy.

When you express an interest in our work, donate, or show a potential to give to our work, we will rely on our legitimate interest to collect additional information as noted in “How we collect information about you”. This helps us to ensure we use our supporters’ money in the most effective ways.

How and when we collect information about you

We obtain personal information from you when you directly interact with us, as well as when you indirectly interact with us. We won’t do anything with your information you wouldn’t reasonably expect.

When you directly provide us with information

We may collect and store information about you, such as when you:

• Support our work through a donation
• Set up a Direct Debit or Standing Order and/or any enquiries you have relating to finance
• Visit our website, for example, the pages you visit and how you navigate the site, and we do this by using cookies. Please see our cookies policy for more information.
• Order from our online shop
• Set up a child sponsorship
• Sign up to receive our publications or prayer focus
• Contact us with an enquiry
• Provide us with your feedback
• Fundraise on our behalf
• Register for an event
• Request a speaker
• Complete a survey
• Apply for a job
• Enter into a contract with us
• Interact with us on social media platforms e.g. Facebook, Twitter or LinkedIn. The information we receive will depend on the privacy preferences you have set on each platform and the privacy policies of each platform. To change your settings on these platforms, you will need to refer to their individual privacy policies.

When you indirectly provide us with information

In some circumstances, we also receive information about you from third parties that provide us with data to help us understand how we can provide the best experience for our supporters and how to best connect with you; or from fundraising sites like Just Giving or Virgin Money Giving, where you have agreed to support Smile International and have given your consent.  (Please check their privacy policies to find out more information on how they will process your data.)

When you give permission to other organisations to share or it is available publicly.

From other sources

• We may use the Royal Mail’s postcode finder, National Change of Address update (NCOA®) or the electoral roll, to check the accuracy of the address or information we hold for you. We will not use these sources to create data that you have chosen not to provide, for example, if you have left an email address blank or a telephone number blank. If you are a regular donor, a person or organisation that continues to donate regularly, and our mailings are returned to us, we may use external sources to update your address details so that we may update you on how your money has been spent through our FEED programmes.
• Information made available publicly by Charity Commission, Companies House or information that has been published in newspapers and articles.

Profiling our supporters, targeting communications and analysis

• We may occasionally, for the purposes of our legitimate interests, use your personal information to conduct profiling of our supporters or potential supporters. This will help us target communications in a more focused, efficient and cost-effective way, helping us reduce the likelihood of supporters and potential supporters receiving inappropriate or irrelevant communications. For this purpose, we may analyse geographic, demographic and other information relating to our supporters. Such information is compiled using publicly available data about you from newspaper or other media coverage, open postings on social media sites and data from Companies House.  You can object to such use of your personal information for profiling at any time by contacting us at the details set out at the beginning of this privacy policy.
• As a registered charity, we are subject to a number of legal and regulatory obligations and standards. The public naturally expect charities to operate in an ethical manner and this is integral to developing high levels of trust and demonstrating our integrity.
• This means that we may carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering.
• We may carry out background checks and due diligence on potential donors or anyone planning on making a significant donation or gift before we can accept it.
• We may conduct analysis of supporters by group, post code or particular area where supporters may be based. This is to ensure that mailings are sent to those who will be most interested or likely to respond. This type of activity is not aimed at identifying specific individuals to target, but rather many individuals who may fall within a certain segment of supporters.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to individual needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

We use two types of cookie:

• Session cookies – these expire when you close your browser and do not remain on your computer.
• Persistent cookies – these are stored in the longer term on your computer. They are normally used to make sure the site remembers your preferences.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

• whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the EU General Data Protection Regulation (GDPR). If you would like a copy of the information held on you please write to us at the address on the contact page.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

What information we may collect

When you engage with us by phone, mail, in person or online, we may collect information about you. This may include your name, address, email address, telephone number, date of birth, job title and details of your education and career, financial information (like account information and credit/debit card numbers) and other information relating to you personally, which you may choose to provide to us.

Your contact information is used to administer any one-off or regular giving donations you make, to get in touch with you when necessary, for example, to be able to fulfil an online order, respond to a request for literature or information, or send an acknowledgement letter or email for a donation. We will use your personal information to reclaim tax on Gift Aid donations, if applicable. We also collect and use personal information for other essential internal record keeping purposes.

We may record your image on CCTV which we use to prevent crime and keep our people and the public safe.

If you use your credit or debit card to donate to us, either via phone, mail or online, or order something online, we pass your card details securely to our payment-processing partner as part of the payment process. We do this in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and we don’t store the details on our website or database.

Data protection law recognises that certain types of personal information are more sensitive. This is known as ‘sensitive’ or ‘special category’ personal information and covers information such as racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person’s sex life or sexual orientation.

Sensitive information will only be collected where necessary, for example, if we need to collect health information from you when you register for a challenge event, such as a Marathon, or assisting as a volunteer or a member of staff. Clear notices will be provided at the time we collect this information, stating what information is needed, and why. With your explicit consent, we may also collect sensitive personal information if you choose to provide it to us.  We may also collect information from you if you tell us about your experiences. All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer required, is never shared with third parties, and is available to you at any point should you wish to see it.

Vulnerable individuals

We understand that additional care may be needed when we collect and process the personal information of vulnerable supporters and volunteers. In recognition of this, we observe good practice guidelines in our interactions with vulnerable people.

 Users 17 and Under

We will not knowingly collect or solicit personal information from anyone aged 17 or under or knowingly allow such persons to provide us with their personal information without parent or guardian consent.

In the event that we learn we have collected personal information from anybody aged 17 or under and do not have the consent of a parent or guardian, we will delete that information as quickly as possible. If you believe that we might have any information from or about anybody aged 17 or under without the consent of a parent or guardian, please contact us on 03300881747 (Monday to Friday, 9am to 5pm).

If you are aged 17 or under, please obtain your parent/guardian’s permission before using our website.

Who do we share your information with?

We will never sell, rent or trade your personal data. We may disclose your data to our overseas partners in relation to child and beneficiary sponsorships, but this is always limited data for the purposes of administering our sponsorship programme, and to service providers who provide services to us or you on our behalf. There are occasions when we may share your information with others and we will only share your data for the following purposes:

• Third party suppliers: We may need to share your information with data hosting providers, website developers and administrators, service providers who help us to deliver our services, projects, or fundraising activities and appeals, payment service providers, HMRC, banks, legal advisors and accountants and auditors. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations.
• Where legally required: We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else. Your data is only processed outside the EU where Smile International has verified that appropriate standards and safeguards are in place. If false or inaccurate information is provided and fraud is identified, we will pass these details to fraud prevention agencies.  Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when sending money overseas to run our projects and when checking details of job applicants and employees.
• Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services.  This may include connecting data we receive from you on the website to data available from other sources.  Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us.  In the case of this activity the following will apply:

1. Your data will be made available to our website provider
2. The data that may be available to them include any of the data we collect as described in this privacy policy.
3. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
4. They will store your data for a maximum of 7 years.
5. This processing does not affect your rights as detailed in this privacy policy

We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this privacy policy.

How long we keep your information

We will hold your personal information on our systems for as long as is necessary for the relevant activity and in accordance with legal requirements. For example, we will keep a record of donations subject to Gift Aid for at least seven years to comply with HMRC rules. We really appreciate it if you let us know if your contact details change.

When your information is no longer required, we will ensure it is disposed of in a secure manner.

If you ask us to stop sending you information, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

As with all charities, Legacy income is vital to the running of our charity. We may keep data you provide to us indefinitely, to carry out legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyse the source of legacy income we receive.

Where you contribute material to us, e.g. user generated content or in response to a particular campaign, we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.

We may have already collected information about you when you donated, whether that was a one-off donation or regular giving, commenced a child or other beneficiary sponsorship programme, you went on a specific trip, you helped us as a volunteer or were a previous member of our staff.  This information is stored securely and is retained purely for historical and analytical purposes. Only named and authorised personnel have access to such data.

Your rights in relation to your data 

You have a right to ask us to stop processing your personal data, and you have a right to ask to access your personal data and to obtain certain information

If there are any discrepancies in the information we provide, please let us know and we will correct them. If you want to access your information, send a description of the information you want to see and by post to Smile International, PO Box 171, Bourne, PE10 1FB or via email. We will then ask you to prove your identity before proceeding with your request. All enquiries will be completed within 30 days of the original request.

In some circumstances, such as when the data is no longer required or if the use of the data has no legal justification, you have the right to have that data erased, as well as the right to object to our handling of your data.

You have the right to withdraw your consent at any time when we rely on consent as a legal ground to justify our handling of your personal data.  This would not affect the lawfulness of anything done before consent is withdrawn but it would stop us from continuing to use the relevant information.

You also have the right to lodge a complaint with the Information Commissioner’s Office about how we manage your data.

Changes to our Privacy Policy

Our privacy policy may be updated at any time, so please check it from time to time.  We may, for example, change the way we process your information, or there may be a change in law.  If we make any significant changes to this policy, we will show this clearly on our website. This policy was last updated in November 2023.

Thank you from everyone at Smile International for your wonderful support.