Privacy policy
Who we are
Unlock Democracy is a company limited by guarantee based in England with administrative offices at 2nd Floor, North Wing, 55 Broadway, London SW1H 0BB. We operate as a non-profit membership organisation with a goal of building a vibrant, inclusive democracy that puts power in the hands of the people.
Where Unlock Democracy is processing your information, including in relation to our campaigns and policy work or your membership, for the purposes of data protection legislation, it is a controller of your personal information. Its registered address is 2nd Floor, North Wing, 55 Broadway, London SW1H 0BB.
This notice applies to personal information we collect about you when you interact with us (for example when you use our websites such as www.unlockdemocracy.org.uk), or that we collect from third parties, as described in this privacy notice. It sets out:
what information we collect, and from whom;
how we use that information;
whom we share your information with;
how your information is protected;
your rights in relation to the information we hold about you; and
how long we keep your information.
We keep our privacy notice under regular review, and we encourage you to periodically review this page for the latest information on our privacy practices. Any material changes will be notified to you by updating them on our websites, together with any such other methods as may be appropriate.
What information does Unlock Democracy collect?
Information you provide to us voluntarily
You may give us your personal information when you:
opt-in to receive email, postal or telephone communications from us by interacting with our campaigns;
use, or provide a comment on our websites;
correspond with or contact us;
interact with us on social media platforms;
sign up to one of our newsletters or other communications;
apply to become a member;
make a donation to us; or
otherwise interact with us or provide information to a third party to be referred to us.
Where we request information from you, we will collect the information set out in the relevant forms or pages, or as explained to you over the telephone. You may choose to provide additional information to us when you contact us or otherwise interact with us or provide information to a third party to be referred to us.
Information we collect from third-party sources
On occasions, we acquire information from another company, for example to supplement the data that Unlock Democracy holds. Where this happens, we will take appropriate steps to assure ourselves that your information was collected legally.
Information we collect automatically
We, or the companies which work on our behalf, collect data related to visitors to our websites automatically, including what pages you have viewed, for how long and your website journey.
Information is also collected about how you arrived at our websites in the first place, including what links or adverts of ours you have viewed or clicked on to reach us, or any search terms you have used. Where you see an advert for us outside of our websites, for example on social media, we will place a cookie on your browser so that, when you access our websites, we recognise that you have seen an advert of ours elsewhere. Information collected automatically using cookies or other tracking technologies includes your IP address.
Information which is available publicly
Your personal information may be available to us from external publicly available sources: for example, geo-demographic information and information from public registers such as listed directorships, information from the electoral roll and press reports. In addition, depending on your privacy settings for social media services, we may access information from those accounts or services.
2. What types of information does Unlock Democracy process?
We collect, store and use the following types of information:
your name and contact details (including your postal address, telephone number, email address(es), your membership number and social media identity);
financial information such as bank details or credit/debit card details where you provide this to make a payment;
details about your membership and donations;
Information you provide on your political preferences and membership of other organisations
information you provide on other individuals (for example dependants);
correspondence you have had with us;
comments you have left on our websites;
your contribution to any research you take part in;
information about your computer/mobile device and your visits to and use of our websites, including for example your IP address;
details about you that are stored in documents in different formats, or copies of them; and
any other information shared with us as described in section 1 above.
3. How does Unlock Democracy use my information, and on what legal basis?
The following sections describe in more detail how Unlock Democracy may use your information, and in particular the legal grounds on which we rely in doing so.
What we use your personal information for
We use the information collected for a number of purposes, including:
to verify your membership;
to make and manage payments;
to manage our relationship and communicate with you;
to respond to complaints and seek to resolve them;
to enhance your online experience;
to conduct research and surveys;
to better understand our members and supporters in general;
to research members’ and supporters’ views and experiences for research and editorial purposes, including through requests for help and surveys;
to respond to individual experiences shared with us and for editorial content;
to understand your website journey, including what pages you have viewed and for how long;
to improve the effectiveness our campaigns;
to administer and keep safe and secure our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to train our staff and measure the quality of the service we give you; and
to obey laws and regulations that apply to us.
The legal grounds we rely on to process your information
The legal grounds on which we rely are:
to fulfil our contractual obligations (for example in order to provide services requested by members and to contact you if a problem arises with them);
to pursue our legitimate interests (for example to facilitate your use of our websites, or for marketing);
your consent; and / or
to fulfil a legal duty.
Legitimate interests
When we rely on our legitimate interests, these are as follows:
keeping our records up to date;
charging for membership;
developing our membership offer;
marketing our products and services;
administering our websites and keeping them safe and secure;
ensuring that content is presented in the most effective manner for you and your devices;
facilitating your use of our websites;
measuring the use of our websites and improving their content and accessibility;
measuring and understanding the effectiveness of advertising, and delivering relevant advertising to you;
tailoring content and our communications so that they are most relevant to you;
carrying out campaigns work and developing Unlock Democracy policy;
complying with legal and/or regulatory requirements;
identifying trends in member and supporter behaviour;
informing and generating content (for our campaigns and policy work).
4. Who does Unlock Democracy share my information with?
We, or one of the companies who work on our behalf, share your personal information with the following third parties:
Data processors
To help us fulfil contracts and to pursue our legitimate interests, we share your personal information with third parties who provide services to Unlock Democracy or who act on our behalf, for instance vendors, IT and other suppliers, research agencies, payment processors, financial institutions, or postal authorities that are involved in fulfilling your request. We do not authorise these companies to use or disclose your personal information except for the purpose of providing the service we request of them. Unlock Democracy is based in the UK, but some third-party data processors will be based outside of the European Economic Area (EEA).
We use Stripe, Paypal, and Crowdfunder to process one-off donations and recurring payments. More information on how Stripe, Paypal, and Crowdfunder process your personal data and your data protection rights, including your right to object, is available at -
https://www.paypal.com/myaccount/privacy/privacyhub
https://www.crowdfunder.co.uk/privacy-policy
We use GoCardless and Access Paysuite to process your Direct Debit payments. More information on how GoCardless and Rapidata process your personal data and your data protection rights, including your right to object, is available at -
https://rapidataservices.com/terms-conditions/
We use Engaging Networks as our database, email and digital tools platform. You can read their privacy policy here - https://www.engagingnetworks.net/assets/uploads/2020/06/Data-Protection-Policy-FINAL-as-of27050.pdf
We use Google Drive for our internal file storage. You can read their privacy policy here -
https://policies.google.com/privacy?hl=en-GB
We use Typeform for carrying out surveys of members and supporters to help improve our campaigns. You can read their privacy policy here -
https://admin.typeform.com/to/dwk6gt?
We use Squarespace as our website provider. You can read their privacy policy here -
https://www.squarespace.com/privacy
We use Meta advertising to publicise our campaigns and to grow our supporter base. If you have agreed to receive email communications from us, we may provide your email address in an encrypted format to Meta for the purposes of identifying people with similar interests to yours who we can display our advertising to.
This data is not retained by Meta and is not used for any other purpose by them. You can opt out of your data being used in this way by contacting us at info@unlockdemocracy.org.uk. Meta’s privacy policy can be found here -
https://www.facebook.com/privacy/policy/
We analyse the use of this website using Google Analytics, which uses cookies (see below for additional information about cookies) to generate reports. Such cookies may contain your information, in which case Google will store this information. Google’s privacy policy is available at -
http://www.google.com/privacypolicy.html
Other circumstances in which we will disclose your information
We will disclose your information to local and foreign regulators, governments, law enforcement authorities, advisors, courts, tribunals and arbitrators when we have a legal obligation to do so or when we believe our compliance with the request to be fair, reasonable and lawful, eg to detect, prevent or investigate security breaches, fraud or other crimes.
We will also disclose your information to establish, exercise or defend legal claims, for example: (i) to enforce our terms & conditions; (ii) to ensure the safety and security of our users, consumers and third parties; and (iii) to protect our rights and property and the rights and property of our websites’ visitors, consumers and third parties.
Location of third parties
Some potential recipients of your information might be located outside the European Economic Area (“EEA”), in jurisdictions which do not have the same data protection laws as those in the EEA. If we do transfer your information outside the EEA we will take appropriate steps to protect that information, which include:
transferring to third parties in jurisdictions that the European Commission has determined offers adequate protection for your information (and information relating to adequacy decisions made by the European Commission are available here); and
entering into an agreement with the recipient, which includes clauses that the European Commission has determined offers adequate protection for your information (a template copy of which is available here).
5. What are my data protection rights?
You have the following rights in relation to your personal data:
Access: The right to request access to and a copy of your personal information (which can be done by emailing info@unlockdemocracy.org.uk);
Restriction: You can ask us to pause processing your information in certain circumstances (eg you are disputing its accuracy);
Rectification: You can have any inaccuracies in your personal information corrected;
Deletion: You can ask us to delete all your personal information in certain circumstances (eg if the information is no longer necessary for the purposes for which it was collected);
Objection: You can object to us processing your personal information in certain circumstances;
Objection to marketing: Please see section 7 (Marketing and advertising) below, for information about how to opt-out of direct marketing communications;
Portability: You can ask us to transfer your information electronically to you or another organisation in certain circumstances;
Withdrawal of consent: Where we rely on your consent to process your information, you can withdraw consent at any time, although this will not affect our uses of your personal information prior to the withdrawal of your consent; and
To lodge a complaint with the Information Commissioner’s Office (“ICO”) or other relevant supervisory authority: You can complain to the ICO (ico.org.uk/global/contact-us/email) or other relevant supervisory authority about any aspect of our handling of your information.
More information about the right to complain can be found at https://ico.org.uk/for-the-public. If you have any questions about these rights, or you would like to exercise them, please contact us using the details at section 10 (How can I contact Unlock Democracy about its privacy notice?) below.
Please be aware that you are under no obligation to provide us with your personal information. However, failure to do so may, in some circumstances, prevent us from being able to provide you with services, or otherwise interact with you.
When exercising your data protection rights we may ask you to verify your identity in order to help us respond efficiently to your request.
If you would like to exercise any of the above rights, please email or write to us using the details outlined in section 10 (How can I contact Unlock Democracy about its privacy notice?) below. All of these rights are free to exercise and we will do our best to respond to you as quickly as possible and in any event, within one month of receipt of your written request. We will inform you within one month of receipt of such a request if we will need longer to respond, for example due to the complexity of the request.
We want to make sure that your personal information is accurate and up to date. Please always let us know if you think that it is not and needs updating. Details of how to get in touch are in section 10 below.
6. How long is my information retained?
Whenever we collect or process your personal data, we will only keep information about you for as long as we need to fulfil the purposes for which we are processing your information or for an appropriate retention period thereafter. At the end of that retention period, your data will either be deleted or anonymised. Examples of our retention periods are:
Where you are a member, we would normally keep your information for the duration of your membership and then a period of up to five years after you cease being a member.
Where we need to keep your information for financial reporting obligations, we would normally keep it for five years from the date of payment.
Where we need to keep your information relating to complaints you have made, we would normally keep it for five years from the end of that matter.
7. Marketing and advertising
We may use the information you provide to send you communications about Unlock Democracy’s Membership or campaign work. This might be by telephone or postal marketing in furtherance of our legitimate interests, or for marketing by email, with your consent.
You can change your marketing preferences at any time by clicking on the “unsubscribe” link in the footer of our emails, or by writing to us or emailing us. All details can be found in section 10 (How can I contact Unlock Democracy about its privacy notice?) below. You can also unsubscribe from receiving any further marketing communications.
We may analyse the information we collect about you to improve the targeting of communications. If you do not wish your data to be used in this way, please contact us at info@unlockdemocracy.org.uk or using the details in section 10 below.
We use tracking technology (by way of a clear image gif) within our emails to improve our future interactions with you. This means we are able to capture information including (but not limited to) the time and date you open our emails and the type of device used to open the email.
We use this information primarily to understand, at an aggregate level, whether our emails are opened and what links are clicked on by our audiences. We then use this information to improve the emails and other communications (including post, SMS and digital advertising) that we send or display to you, and the services that we provide, and to evaluate the effectiveness of our campaigns. We may also use this data to clean our list to ensure that only people who are engaged with us continue to receive communications
You can turn off email tracking by disabling automatic picture download within your email client's settings.
8. Links to other websites and social media
Where we provide links to other websites, we do so for information purposes unless otherwise indicated. The other websites are outside our control and are not covered by this privacy notice. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy notice, which may differ from ours.
On some pages of our websites, third parties that provide content, applications or plug-ins through our websites may track your use of content, applications and plug-ins or customise content, applications and plug-ins for you. For example, when you share an article using a social media sharing button on our websites (e.g., Facebook or Twitter), the social network that has created the button will record that you have done this.
9. Use of our websites by minors
If you are aged 13 or under, please get your parent's/guardian's permission before you provide information to us via our websites. Users without this consent are not allowed to provide us with information and, in the event that they do so, we will cease to process their information as soon as we find out.
10. How can I contact Unlock Democracy about its privacy notice?
You can contact us by email and post as follows:
Email: info@unlockdemocracy.org.uk
Postal Address: Unlock Democracy, 2nd Floor, North Wing, 55 Broadway, London SW1H 0BB
To find out more about Unlock Democracy and who we are, please look at the ‘About’ section of our website, www.unlockdemocracy.org.uk
11. Changes to this Privacy Notice
Unlock Democracy may need to update this Privacy Notice from time to time. You can see when the Privacy Notice was last updated by checking the date at the top of the page. A summary of changes can be found in this section, along with the date they were made.
If we make any updates, such as materially changing how we use your personal data, we will alert you as required by applicable privacy laws.
The privacy policy will be reviewed every year.
21.4.21 New privacy policy adopted.
21.4.22 Privacy policy reviewed
23.8.23 Privacy policy review and updated
12.4.24 Privacy policy reviewed