Privacy and Cookies Policy
We are Clear Heads International Limited.
We provide the Go Sober Website (at https://www.gosober.org.uk) (the Go Sober Website); and the Go Sober program (Go Sober) on behalf of Macmillan Cancer Support.
We respect, and are committed to protecting your right to privacy. This Go Sober Privacy and Cookies Policy (the "Privacy and Cookies Policy") sets out:
- how we may collect your personal information;
- how we will handle the personal information which we collect; and
- how and why we may use and disclose this information from time to time.
This Privacy and Cookies Policy forms part of "Our Agreement". Our Agreement comprises: (a) the Terms and Conditions (available here: https://www.gosober.org.uk/terms-and-conditions), (b) this Privacy and Cookies Policy; (c) policies, notices and disclaimers displayed elsewhere on the Go Sober Website; and (d) the Payment Terms. By agreeing to Our Agreement, you consent to the collection, and use and disclosure of your personal information as described in this Go Sober Privacy and Cookies Policy.
We may review and update this Go Sober Privacy and Cookies Policy from time to time to take account of, for example, new laws, technology and changes to Go Sober or the Go Sober Website. We will notify you of any updates or amendments through regular notifications posted on the Go Sober Website. We will also notify you on this page. Any updates or amendments to this Privacy and Cookies Policy will take effect on and from the day that such update and/or amendment is published on the Go Sober Website.
It is your responsibility to check for any updates or amendments and you should review this page regularly.
You should not be a Participant (as defined in the Terms and Conditions) with Go Sober, make any donations or place any purchase orders on the Go Sober Website, or access or use the Go Sober Website if you do not agree to anything in this Go Sober Privacy and Cookies Policy. This Go Sober Privacy and Cookies Policy was last updated on 11 August 2016.
You should direct any questions or complaints to our Data Protection Officer at [email protected].
Personal information which may be collected by us
We may collect the following personal information:
1. Information relating to Your Account: In accordance with Our Agreement we require all Participants to have an active account with us (Account). To open your Account you must provide us with certain personal information and we will collect and hold this information. Such information may include your [name, address, email address, phone number and financial and credit card information]. We require this to be able to identify you and for security purposes. If you choose not to provide the personal information we request, we will not be able to let you open or keep open your Account. We may also collect information relating to your use of your Account.
2. Your Content: You may post on or make available to the Go Sober Website your content and information, including information about you and the actions you take, any photos, video, or text or other forms of content (Your Content). Your Content will be publicly available. You grant us a licence to Your Content under Our Agreement.
3. Being a part of Go Sober: If you are a Participant or Donor (as defined in the Terms and Conditions), we may collect and hold information in relation to your participation with Go Sober. This may include information such as who you sponsor or who sponsors you, donations made by you or related to you (if you are a Participant) and purchase orders placed by you. If you choose to use our opt-in services, we will ask you for the information needed to send the communication or have it sent to you and we may keep information about our communications with you.
4. Using the Go Sober Website: We collect and hold details of your access to and use of the Go Sober Website. This includes your browser type and IP address [and technical information such as the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page]. In addition, we store certain information from your browser using "cookies". For more information on the "cookies" we use, please read the section below.
6. Our cookies will not allow us to obtain information of a personal nature that will identify you to us, such as your name and address. We will only be aware of such information if you provide the information to us, or you have set the preferences in your browser to provide this information automatically.
7. Details of the cookies we use are as follows.
(a) Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Go Sober Website and use its features. We use session ID cookies to confirm that users are logged in. These cookies terminate once the user closes the browser and they can be removed or blocked using the settings in your browser. Without these cookies however, the services you have asked for may not be capable of being provided.
(b) Performance Cookies: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Go Sober Website works. By using the Go Sober Website, you agree that we can place these types of cookies on your device.
(c) Functionality Cookies: These cookies allow the Go Sober Website to remember choices you make and provide enhanced, more personal features.. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. By using the Go Sober Website, you agree that we can place these types of cookies on your device.
More information about the individual cookies used on the Go Sober Website is detailed in the table below:
Set when you arrive at the site and is deleted when you close the browser. The cookie stores the session key that is generated for each user. The cookie may be used for logs and system maintenance.
The __cfduid cookie is used to override any security restrictions based on the IP address the visitor is coming from. For example, if the visitor is in a coffee shop where there are a bunch of infected machines, but the visitor's machine is known trusted, then the cookie can override the security setting. It does not correspond to any userid in the web application, nor does the cookie store any personally identifiable information.
Note: This cookie is strictly necessary for site security operations and can't be turned off.
8. Your web browser may allow some control of most cookies through your browser settings. To find out more about cookies, including how to see what cookies have been set on your computer and how to manage and delete them, visit www.allaboutcookies.org. Please note that you may delete and block all cookies used by this website, but if you do so parts of the site may not work.
Information we will not collect
9. We do not collect any credit card or debit card information from you.
10.All donations and payments are made through the Datacash Payment System (http://www.datacash.com) (Payment System). The provider of the Payment System may retain your payment and credit card details. We do not collect or hold your credit card information, either from you or from the Payment System provider. Click here (http://www.datacash.com/privacy.php) to view the Payment System provider's Privacy and Cookies Policy.
Use of your personal information
11. Your personal information may be used by us to:
- verify your identity;
- if you are a Participant, enable you to open and use Your Account;
- if you are a Participant, have a profile page on the Go Sober Website;
- enable you to be a Participant or Donor;
- enable you to otherwise access and use the Go Sober Website, including uploading and sharing Your Content;
- troubleshooting and rectifying or altering Go Sober;
- facilitate the sharing of Your Content;
- administer and manage Go Sober and the Go Sober Website;
- administer and manage your access to and use of the Go Sober Website;
- carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that your request;
- communicate with our Payment System;
- maintain, undertake research into and develop Go Sober and the Go Sober website;
- improve the Go Sober Website to ensure that content is presented in the most effective manner for you and your computer;
- allow you to participate in the interactive features of our service, when you choose to do so; and
- communicate with you, or permit other people to communicate with you, in accordance with Our Agreement.
12. We will only use your information to provide you with details of products and services you have requested. We may use the following marketing methods to communicate with you: post, telephone, email and SMS. If at any time you do not wish to receive such communications, then you may opt out by emailing or writing to us (see "Contact us", above) or by calling 0300 1000 200.
Other people's information
13. If you provide to Go Sober or post on or make available to the Go Sober Website any personal information of another person, you must:
- have that person's prior written consent to do so;
- ensure they are aware of this Privacy and Cookies Policy; and
- ensure their consent allows us to use and disclose their personal information in the same way that we may use and disclose your personal information.
Disclosure of your personal information
14. In order to be able to manage Go Sober and operate the Go Sober Website, we may disclose your personal information to third parties for the following purposes:
- if you are a Participant, to open and use your Account;
- so you can access and use the Go Sober Website, including uploading and sharing Your Content;
- so we can administer, manage and support Go Sober and the Go Sober Website for you (including your access to and use of the Go Sober Website);
- so we can ensure your donations and purchase orders are properly accounted for with the Payment System provider;
- so we can fulfil your purchase orders;
- so we can undertake research into and develop Go Sober and the Go Sober Website to make it better.
- For these purposes, the third parties:
- carry out IT services for us related to Go Sober and the Go Sober Website including our physical housing, monitoring and backup of the servers for the Go Sober Website, support and maintenance for the Go Sober Website;
- are the Payment System provider;
- provide services to enable fulfilment of your purchase orders;
- carry out marketing, market and participation research for us but your personal information will only be provided on a de-identified basis unless you otherwise consent;
- provide us with support, sponsorship or are beneficiaries, but your personal information will only be provided on a de-identified basis unless you otherwise consent.
15. If you are a Participant we will display your name and image on your profile page of the Go Sober Website. Your email address or other contact information will not be displayed in any form through the Go Sober Website. If you are a Donor we will normally display your name on the profile page of the Participant to whom you have made a donation. When making a donation, you have the option of checking a box marked "Anonymous Donation". If you check this box, your name will not be disclosed to the Participant nor will your name be displayed on the Go Sober Website.
16. If you are a Participant, we may also provide your postcode information from your Account to Google Maps (but not other personal information) so Google Maps can display information about participation in Go Sober. This is unlikely to be able to identify you.
17. We may also disclose information to third parties you have indicated you want to share your information with for a particular purpose, including through opting in to a particular form of communication (by checking a box or by other means that allows Go Sober to pass your information onto third parties). This may include beneficiaries, third parties that provide goods or services, or our sponsors who may wish to contact you from time to time. Please note that unless you provide consent your personal information will not be provided to these people on an identified basis.
18. We take reasonable steps to ensure that any third parties who we disclose your personal information to are bound by confidentiality and privacy obligations in relation to the protection of your personal information. We will use all reasonable efforts to de-identify your personal information and to disclose personal information on an anonymous basis. We will not transfer your personal information to third parties for marketing purposes unless you have specifically agreed to such disclosure.
19. In addition, we may disclose your personal information to:
To safeguard the confidentiality of your personal information, we implement technical and organisational security measures in line with industry standard practices. Our web servers are housed behind a secure firewall that prevents access to our databases from unauthorised users. All of our servers are housed in a secure environment and is protected by physical security, together with limiting access to authorised staff only. Even though we maintain security measures in line with industry standard practices, we cannot 100% guarantee (and you should not expect) that personal information you submit to a website or communications over the Internet will always remain private. For example (and without limiting the previous statement), although we take the steps referred to above, third parties may unlawfully intercept your communications, or unlawfully access our system or other networks which are connected to the Internet. Transmission of your personal data is at your own risk.
Changes to personal information
20. Management of personal information in your Account and Your Content is governed by you. You are responsible for changing these as required by you from time to time.
21. You are responsible for ensuring that the personal information we collect, use and disclose and which you use and disclose to us is accurate, complete and up-to-date. To the extent possible, we will take reasonable efforts to assist you in ensuring this is the case. We ask that you let us know if there are any errors in your personal information which we have collected and keep us up-to-date with changes to your personal information which we have collected such as your name or e-mail address.
22. If you have difficulty in doing this, you should contact us for help by emailing us at [email protected]
Telling you what information we hold about you
In accordance with applicable law, you have a right to receive information about the personal information that we hold or process about you from time to time. If you wish to know what information about you we hold or wish to make any request in accordance with your rights under applicable data protection law please contact us by email at: [email protected] or by post at the following address:
Macmillan Cancer Support
89 Albert Embankment
23. Please note that we reserve the right to request further information to verify your identity or locate the specific information that you seek before responding to any request.
Removing and correcting information
If you request us to remove your personal information from our database or you wish us to amend or change the information we hold about you on our database, we will remove amend or change any such information on your request in accordance with your rights under applicable law. Such request should be made by email at [email protected] or by post at the following address:
Macmillan Cancer Support
89 Albert Embankment
Or by calling 0300 1000 200.
Applicable law and jurisdiction
24. The terms of this Privacy and Cookies Policy shall be governed by English Law, and the parties irrevocably submit to the non-exclusive jurisdiction of the courts of England for the purpose of hearing and determining any dispute arising out of or in any way relating to this Privacy and Cookies Policy and for the purpose of enforcement of any judgment.