Who we are?
GambleAware is an independent charity (Registered Charity 1093910, Registered Company Number 4384279) tasked to fund research, education and treatment services to help to reduce gambling-related harms in Great Britain.
2a Charing Cross Rd
London WC2H 0HF
What do we do?
GambleAware is a commissioning and grant-making body, not a provider of services. Guided by the National Responsible Gambling Strategy, the charity’s strategic aims are to: broaden public understanding of gambling-related harms, in particular as a public health issue; advance the cause of harm-prevention so as to help build resilience, in particular in relation to the young and those most vulnerable to gambling-related harms; and help those who do develop gambling-related harms get the support that they need quickly and effectively.
The objects of the charity are here.
As you browse our website, get in touch with us, or provide donations to us we collect personal information. This deepens our understanding of what you are interested in, and helps us to improve the efficiency of our work.
GambleAware will never exchange or sell your information to another organisation for their own marketing purposes. We know that this is important to you, and want to reassure you that you’re always in control of how we use your personal information in regards to marketing and fundraising activities.
We do however need to collect and use your personal information for carefully considered and legitimate business purposes, which help ensure we can run GambleAware efficiently, raise funds effectively and meet our charitable objects. This policy explains how your personal information will be used, what data we collect, our legal basis for its use, along with outlining your rights in respect of personal information.
Purposes for which your personal information are processed
In simple terms, your personal information may be used to help us effectively meet our charitable objects or to help us raise funds for those charitable activities we commission.
We always strive to provide a clear, honest and transparent approach regarding how and when we may collect and use your personal information. The overview below summarises the different reasons why we do this. We may not use your personal information for all of these purposes – it will depend on the nature of our relationship with you, and how you interact with our charitable and fundraising activities, and websites:
For the establishment, defence or enforcement of legal claims.
GambleAware needs a lawful basis to collect and use your personal information. The law sets out six lawful bases. The following are relevant to GambleAware’s use of your personal information:
We may also share your personal information where we are compelled by law to do so.
If you are an individual rather than a company, GambleAware will ask for your consent to send you marketing and fundraising emails. You can withdraw consent at any time by contacting us at firstname.lastname@example.org.
b) Contractual relationship
We will process your personal information as necessary for the performance of a contract with you – for example if you are a consultant or sole trader working with GambleAware, or to facilitate a payment.
c) Legitimate Interests
The law allows personal information to be legally collected and used if it is necessary for a legitimate interest (which could be that of the organisation, a third party, or the individual) - as long as its use is fair and balanced and does not unduly impact the rights of the individual concerned.
There are times when it is neither practical nor appropriate to ask a person for consent. In many situations, the best approach for GambleAware and our supporters is to process personal information on the basis of our legitimate interests, rather than consent.
Please read our Legitimate Interests Statement below.
Personal information collected
We collect and use personal information such as name and address details along with other contact information such as email addresses and telephone numbers. We also collect information about the services you use, any purchases or financial transactions you make (including payment details), or any marketing contact preferences you give. We maintain a record of communications we send to you and we will log any communications that you send to us.
Do we process ‘sensitive’ personal information?
Under data protection law, certain categories of personal information are recognised as sensitive and requiring greater protection, including personal information about your health, race, religious beliefs, and political opinions (‘sensitive personal data’, also known as special category data). In limited cases, we may collect sensitive personal data about you, such as information about your health. We would only collect sensitive personal data if there is a clear reason for doing so, such as where we need this information to ensure that we provide you with appropriate information and advice and we will either rely on your explicit consent or rely on a further basis that is in the substantial public interest (e.g. for the provision of confidential counselling, advice or support or of another similar service provided confidentially) or, in some cases, we may process sensitive personal data in order to protect your vital interests.
Where does the personal information come from?
We collect information in the following ways:
You may give us personal information about you by filling in forms on (or downloaded from) our website or by corresponding with us by post, phone, e-mail or otherwise, by making a donation to us, or by fundraising on our behalf. This includes personal information you provide when you register to use our site (if applicable), subscribe to our service, and when you report a problem with our site.
Your information may be shared with us by independent event organisers, for example Charity Challenge or fundraising sites like Just Giving or Virgin Money Giving. These independent third parties will only do so when you have indicated that you wish to support GambleAware and where necessary with your consent. You should check their privacy policies when you provide your personal information to them to understand fully how they will process (and share) it.
We may combine personal information you provide to us with information available from external sources in order to gain a better understanding of our supporters to improve our fundraising methods, products and services.
The personal information we get from other organisations may depend on your privacy settings or the responses you give to them, so you should regularly check your preferences and settings. This information comes from the following sources:
- Third party organisations. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, trade associations, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
- Social Media. Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those accounts or services.
- Information available publicly. This may include information found in places such as Companies House, Gambling Commission Register, Charity Commission Register, and information that has been published in articles/newspapers.
With regard to each of your visits to our site we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including 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 and any phone number used to call our customer service number.
How long we keep personal information
In general, unless we still require the personal information for the purpose for which we collected and/ or process it, we remove your personal information from our records seven years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure under section 10, we will remove it from our records at the relevant time.
If you ask not to receive any further contact from us, we will keep some basic information about you in order to avoid sending you unwanted materials in the future.
GambleAware will not exchange or sell your personal information to another organisation for their own marketing purposes. However, there are some situations where we may have to share your personal information with other organisations, including:
In these situations, the relationship between GambleAware and the third party data processor will generally be governed by a contract and strict security requirements will be in place to protect your personal information. GambleAware will never sell or rent your personal information to other organisations.
We may also disclose your personal information to other organisations:
Data protection rights
Where GambleAware is using your personal information on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to ask GambleAware to stop using your personal information for direct marketing purposes. Simply contact us. You also have the following rights which apply in certain circumstances and subject to exemptions:
Collection of Data through ‘Cookies’
Where we store your personal information
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services.
Unfortunately, no transmission of information via the internet is completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data in transit online. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
What to do if you are not happy?
In the first instance, please talk to us directly so we can help resolve any problem or query. You can contact us using this email address: email@example.com.
You can also register with the Fundraising Preference Service (FPS). This service is run by the Fundraising Regulator and allows you to stop receiving fundraising email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service at www.fundraisingpreference.org.uk or by calling 0300 303 3517. Once you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days.
You also have the right to complain to the Information Commissioners Office (ICO) at any time if you have any concerns about Data Protection using their help line 0303 123 1113 or at www.ico.org.uk
Page last updated July 2018
Legitimate Interests Statement
Data privacy law requires us to have specific lawful reasons in order that we can use (or 'process') your personal information. One of the reasons is called 'legitimate interests'. Broadly speaking Legitimate Interests means that we can process your personal information if we can identify a legitimate interest (which can be ours or another’s), that our use is reasonably necessary to further that interest and we are not harming any of your rights and interests.
If you would like to know more about legitimate interests under data privacy law see the Information Commissioners Office (ICO) website.
This statement explains GambleAware’s legitimate interests.
What are GambleAware's Legitimate Interests?
Generally, GambleAware’s legitimate interests are the running of GambleAware as a charity and a business and pursuing our charitable objects:
(a) The relief of those who are vulnerable or otherwise in need as a result of gambling in particular but not exclusively, by provision of counselling and advice; and
(b) The advancement of education for the benefit of the public by research into responsible gambling, the nature and causes of gambling-related harm and the effectiveness of treatments, and the publication of the results of such research.
This includes (non-exhaustively):
Publicity & Income Generation
Financial Management & Control
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we are processing your personal information based on legitimate interests, you have a right to object to this use which can be exercised by contacting us. Please note that in some cases we will continue to process your personal information where the law allows us to – such as if there are compelling legitimate grounds for the processing which override your interests or if the processing is for the establishment, exercise or defence of legal claims.
Note on corporate fundraising and ‘corporate subscribers’:
Our charity processes personal information to deliver marketing and fundraising content to company representatives working at and/or for corporate bodies and entities who derive an income from the gambling industry in Great Britain, with the aim of obtaining the companies’ support, as well as when sending follow up communications (incl. thank you messages, progress reports, invitation to stewardship events, etc). Moreover, we process personal data from individuals working at and/or for a wide range of relevant stakeholders such as legislators (e.g. Gambling Commission, DCMS, Charity Commission), professional trade associations and professional bodies (e.g. ABB, Lotteries Council, BACTA, Bingo Association, IGRG) and other relevant bodies and organisations (e.g. RGSB).
GambleAware relies on legitimate interest as its legal basis to process personal data and send direct marketing communications promoting our charity and charitable objectives to companies who fall under the ‘corporate subscriber’ category of recipients (as opposed to the ‘individual subscriber’ category of recipients). The law requires us to have consent to send email marketing to ‘individual subscribers’, but not for marketing to corporate addresses. We do so on the basis that:
Please find further guidance on GDPR and Corporate Fundraising produced by the Institute of Fundraising and the Fundraising Regulator here.