Privacy policy
Last updated: 18 February, 2025
fundmore.charity cares about personal data (which we call personal information in this privacy policy). Personal information means any information about an individual which relates to that individual, if that individual is identified or identifiable.
We are registered at the Information Commissioner’s Office (see ico.org.uk) with registration number ZB682342.
This privacy policy sets out how fundmore.charity uses and protects personal information.
1. Important information and who we are
1.1. We are Ensemble Fundraising Limited, trading as fundmorecharity (company number 15643293) with registered office at 17a Southbourne Crescent NW4 2LB.
1.2. This privacy policy sets out how we collect and use personal information through use of our website https://fundmore.charity or our app (together the Site), including any personal information which may be provided on registration on the Site or when making a donation.
1.3. fundmore.charity and any charity that registers on the Site (each charity being a Charity) are independent data controllers. This means fundmore.charity and a Charity each themselves decide how to use personal information to which they have access. However, personal information about individuals using the Site and information from fundmore.charity’s services will be collected by fundmore.charity and some passed to a Charity. To see how a Charity deals with this personal information, please see that Charity’s own privacy policy.
2. The types of personal information we collect
2.1. We may collect, use, store and transfer different kinds of personal information, which we have grouped together as follows:
2.1.1. Identity Data includes first name, last name, username or similar identifier, title.
2.1.2. Contact Data includes email address and telephone numbers.
2.1.3. Transaction Data includes details about payments to and from individuals in terms of donation amounts. However, We DO NOT collect or hold any financial data. This is dealt with directly by a Charity’s payment providers – the identity of a particular payment provider depending on what has been selected by a Charity as a way to pay - and on how a donor decides to donate.
2.1.4. Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices used to access the Site.
2.1.5. Profile Data includes username and password, donations made, preferences and any feedback or survey responses.
2.1.6. Usage Data includes information about how an individual user interacts with and uses the Site and our services.
2.1.7. Marketing and Communications Data includes an individual’s preferences in receiving marketing from us and our third parties and a user’s communication preferences.
2.2. We also collect, use and share aggregated data such as statistical or demographic data which is not personal information, as it does not directly (or indirectly) reveal the identity of any individual. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific Site feature in order to analyse general trends in how users are interacting with the Site, to help improve the Site and our service offering.
3. How do we collect personal information?
3.1. We use different methods to collect personal information including through:
3.1.1. Interactions with us. An individual may give us personal information by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal information an individual provides when making a donation or giving us feedback or contacting us.
3.1.2. Automated technologies or interactions. As an individual interacts with the Site, we will automatically collect Technical Data about that individual’s equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
3.1.3. Third parties or publicly available sources. We may receive personal information about an individual from various third parties and public sources as set out below:
(a) Technical Data is collected from analytics providers, advertising networks and search information providers;
(b) Contact and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe (or others) based inside the UK;
(c) Identity and Contact Data is collected from data brokers or aggregators; and
(d) Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How we use personal information
4.1. Legal basis
4.1.1. The law requires us to have a legal basis for collecting and using personal information from individuals. We rely on one or more of the following legal bases:
(a) Performance of a contract with, or delivery of services to, an individual: Where we need to perform a contract we are about to enter into or have entered into with an individual (such as making our Site available to that individual).
(b) Legitimate interests: We may use an individual’s personal information where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give that individual the best and most secure experience. We make sure we consider and balance any potential impact on the individual and the individual’s rights (both positive and negative) before we process that individual’s personal information for our legitimate interests. We do not use the individual’s personal information for activities where our interests are overridden by the impact on that individual (unless we have the individual’s consent or are otherwise required or permitted to by law).
(c) Legal obligation: We may use an individual’s personal information where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
(d) Consent: We rely on consent only where we have obtained the individual’s active agreement to use that individual’s personal information for a specified purpose, for example if the individual agrees to be contacted about a future charity campaign.
4.2. Purposes for which we will use personal information
4.2.1. We have set out below, in a table format, a description of all the ways we plan to use the various categories of an individual’s personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/use | Type of data | Legal basis |
|---|---|---|
| To register an individual as a new user |
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Performance of a contract with an individual and/or to deliver services to that individual |
| To process and deliver a donation or deal with a fundraiser |
|
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| To manage our relationship with an individual which will include dealing with that individual’s requests, complaints and queries |
|
|
| To enable an individual to complete a survey |
|
|
| To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
|
| To deliver relevant website content and online information to users and measure or understand the effectiveness of the information we serve to users |
|
Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve the Site, products/services, user relationships and experiences and to measure the effectiveness of our communications and marketing |
|
Necessary for our legitimate interests (to define types of users for our services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy) |
| To send an individual relevant marketing communications and make personalised suggestions and recommendations to individuals about services that may be of interest to an individual based on that individual’s Profile Data |
|
Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained an individual’s prior consent to receiving direct marketing communications from specified third parties |
| To pass details of donations and donors to a Charity |
|
|
5. Direct marketing
5.1. During the donation process on the Site when an individual’s personal information is collected, the individual will be asked to indicate preferences for receiving direct marketing communications from fundmore.charity (and/or occasionally from a Charity).
5.2. Also, an individual will receive marketing communications from us if that individual has requested information from us or used our services and that individual has not opted out of receiving the marketing.
5.3. We may also analyse an individual’s Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to that individual so that we can then send that individual relevant marketing communications.
6. Third party marketing
6.1. We will get an individual’s express consent before we share that individual’s personal information with any third party for their own direct marketing purposes.
7. Opting out of marketing
7.1. Any individual can ask us to stop sending marketing communications at any time by following the opt-out links within any marketing communication sent to that individual or by contacting us at
data‑protection@fundmore.charity.
data‑protection@fundmore.charity.
7.2. If an individual opts out of receiving marketing communications, that individual will still receive service-related communications that are essential for administrative or user service purposes.
8. Cookies
For more information about the cookies we use and how to change cookie preferences, please see our Cookie Policy.
9. Disclosures of personal information
9.1. We may share an individual’s personal information where necessary with the parties set out below for the purposes set out in the table in Section 4.2 of this Policy above.
9.1.1. Internal Third Parties as set out in that table, such as our staff.
9.1.2. External Third Parties as set out in that table, such as a Charity (who then “owns” it and deals with it according to their own privacy policy or an IT provider who processes it on our behalf).
9.1.3. 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 personal information we hold in the same way as set out in this privacy policy.
9.2. We require all third parties we deal with to respect the security of personal information and to treat it in accordance with the law.
9.3. We do not allow our third-party service providers to use personal information for their own purposes and only permit them to process personal information we hold for specified purposes and in accordance with our instructions. (A Charity is not a service provider.)
10. International transfers
10.1. We do not transfer personal information outside the UK.
10.2. However, we may transfer personal information to service providers that carry out certain functions on our behalf. This may involve transferring personal information outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Whenever we transfer personal information out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
10.2.1. We will only transfer personal information to countries that have been deemed by the UK to provide an adequate level of protection for personal information; or
10.2.2. We may use specific standard contractual terms approved for use in the UK which give the transferred personal information the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at info@ensemblefundraiusing.com.
11. Data security
11.1. We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal information we deal with on our instructions and they are subject to a duty of confidentiality.
11.2. We have put in place procedures to deal with any suspected personal information breach and will notify any affected individual and any applicable regulator of a breach where we are legally required to do so.
12. Data retention (for how long do we use personal information?)
12.1. We will only retain an individual’s personal information for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.
12.2. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of that personal information, the potential risk of harm from unauthorised use or disclosure of that personal information, the purposes for which we process that personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
12.3. By law, we have to keep basic records and information about donors (including Contact, Identity and Transaction Data) for seven years after they cease being donors for tax purposes.
12.4. In some circumstances, an individual can ask us to delete the personal information we hold about that individual: see below for further information.
12.5. In some circumstances we will anonymise personal information (through an irreversible process so that it can no longer be associated with an individual) for research or statistical purposes, in which case we may use this information indefinitely without further notice to the individual whose personal information was anonymised.
13. An individual's legal rights
13.1. Every individual has a number of rights under data protection laws in relation to that individual’s personal information.
13.2. Every individual has the right to:
13.2.1. Request access to the individual’s personal information (commonly known as a ‘subject access request’). This enables an individual to receive a copy of the personal information we hold about that individual and to check that we are lawfully processing it.
13.2.2. Request correction of the personal information that we hold about the individual. This enables the individual to have any incomplete or inaccurate data we hold about the individual corrected, though we may need to verify the accuracy of the new data the individual provides to us.
13.2.3. Request erasure of the individual’s personal information in certain circumstances. This enables the individual to ask us to delete or remove personal information where there is no good reason for us continuing to process it. The individual also has the right to ask us to delete or remove personal information where the individual has successfully exercised the right to object to processing (see below), where we may have processed the individual’s information unlawfully or where we are required to erase the individual’s personal information to comply with local law. Note, however, that we may not always be able to comply with the individual’s request for erasure, for specific legal reasons which will be notified to the individual, if applicable, at the time of the individual’s request.
13.2.4. Object to processing of the individual’s personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of that data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process the individual’s information which override the individual’s right to object.
13.2.5. The individual also has the absolute right to object any time to the processing of that individual’s personal information for direct marketing purposes (see Section 7 above for details of how to object to receiving direct marketing communications).
13.2.6. Request the transfer of the individual’s personal information back to that individual or to a third party. We will provide to the individual, or a third party the individual has chosen, the individual’s personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which the individual initially provided consent for us to use or where we used the information to perform a contract with that individual.
13.2.7. Withdraw consent at any time where we are relying on consent to process that individual’s personal information (see the table in in Section 4.2 of this Policy above for details of when we rely on the individual’s consent as the legal basis for using that individual’s data). However, this will not affect the lawfulness of any processing carried out before the individual withdraws consent. If the individual withdraws consent, we may not be able to provide certain products or services to that individual. We will advise the individual if this is the case at the time the individual withdraws consent.
13.2.8. Request restriction of processing of the individual’s personal information. This enables the individual to ask us to suspend the processing of that individual’s personal information in one of the following scenarios:
(a) If the individual wants us to establish the data's accuracy;
(b) Where our use of the data is unlawful but the individual does not want us to erase it;
(c) Where the individual needs us to hold the data even if we no longer require it as the individual needs it to establish, exercise or defend legal claims; or
(d) The individual has objected to our use of that individual’s personal information but we need to verify whether we have overriding legitimate grounds to use it.
13.3. If any individual wishes to exercise any of the rights set out above, please Contact Us at data‑protection@fundmore.charity.
13.4. No fee usually required: An individual will not have to pay a fee to access that individual’s personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if any request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with the individual’s request in these circumstances.
13.5. What we may need: We may need to request specific information from an individual to help us confirm the individual’s identity and to ensure the individual’s right to access the individual’s personal information (or to exercise any of the individual’s other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact the individual to ask for further information in relation to any request, so as to speed up our response.
13.6. Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if the individual’s request is particularly complex or the individual has made a number of requests. In this case, we will notify the individual and keep the individual updated.
14. Contact details
Any questions about this privacy policy or about the use of personal information or for the exercise of any privacy rights, please contact us in the following ways:
- Email address: data‑protection@fundmore.charity
- Postal address: Data Issues, fundmore.charity, 17a Southbourne Crescent, NW4 2LB
15. Complaints
15.1. Everyone has the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns before approaching the ICO - so please contact us in the first instance at data‑protection@fundmore.charity.
16. Changes to the privacy policy and a duty to inform us of changes
16.1. We keep our privacy policy under regular review.
16.2. It is important that the personal information we hold about an individual is accurate and current. We would ask that every individual please keeps us informed if personal information changes during that individual’s relationship with us - for example a new address or email address.
17. Third-party links
17.1. The Site 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 an individual. We do not control these third-party websites and are not responsible for their privacy statements. When any user leaves the Site, we encourage that user to read the privacy policy of every website visited.