Privacy Policy

Who are we?

Freedom Church Cheltenham (also referred to as “us”, “our” or “we”) is a registered charity in England and Wales (charity number: 1206262). The primary mission statement of Freedom Church Cheltenham is to connect anyone, anywhere to a life- changing relationship with Jesus; as followers of Jesus, it is also our mission to prevent or relive poverty, or financial hardship; to relieve people in need, who are experiencing hardship, who are distressed, or are aged or sick. You can view a longer version our mission statement on the charity commission website.

Scope of this Policy

This policy covers the use of our website and our other systems that process personally identifiable information. It is not exhaustive as there are processes such as the processing of DBS checks. How we use your data for these processes will be made clear at the time, if it applies to you.

Visitors to our website

When someone visits our website by clicking on a google search advert we use a third-party service, Google Tag Manager, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone individually. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Use of cookies by Freedom Church Cheltenham

By agreeing to this Privacy Policy, you also agree to our Cookies Policy. You can read more about how we use cookies here.

What information do we collect?

We may collect the following information either on our website or in our secure database platform:

• Information about how you use our website and actions that you take on it.
• Contact information, such as, your name, title, address, email address and phone number.
• Profiling information such as your preferences and interests.
• Records of any donations you have made to us (we have a legal obligation to keep this).
• Preference information, such as if you want to receive church communications about upcoming activities or volunteer activities, rotas.
• Any other information that you submit to us via form submissions.

What do we do with the information we gather?

We require this information to understand your needs and provide you with a better service, and also but not limited to the following reasons:

• Internal record keeping.
• We may use the information to improve our communications, services, products and promotions.
• We may periodically send ministry updates, promotional emails about new upcoming events, giving, special offers or other information which we think you may find interesting using the contact information which you have provided, in-line with the consent that is given at the point of subscription.
• We may contact you by email, phone or mail, or through other forms of digital communication such as WhatsApp. We may use the information to our communications according to your interests.
• We will never share your data with other organisations unless we outsource part of our processes to trusted parties (third party providers).
• We will NEVER sell your data to any other organisations for any purpose.
• Process donations and gift aid declaration.

Our legal basis for processing your personal data

• Email, Text and WhatsApp Communications – Consent. We will only send you emails if you have given us your express consent to do so. There are some exceptions this, for example, if we need to contact you regarding a specific donation that you have made, or if it is in response to a communication that you have sent us.
• Donations – Legal Obligation. If you have donated to Freedom Church then we have a legal obligation to keep accurate records of all donation for accounting purposes and to prevent money laundering.
• Gift Aid – Consent. If you donate to Freedom Church and have given us consent to claim gift aid on your donations then we will make those claims to HMRC.
• Church Member Logs – Consent. Everyone who comes to Freedom Church Cheltenham is important to us. If you share your personal information with us, we may use it to keep records of your involvement with our Church such if you are volunteer, or want to take part of a midweek group. We don’t want anyone to miss out through a breakdown of communication so we keep records to ensure that we can support everyone as best we can.
• Data Protection Obligations – Legal. Under the GDPR we have an obligation to ensure that the data we retain about you is up to date and we may contact you from time to time to check that your data is correct.
•  Photographs for marketing purposes – Consent. During our events we may take photographs for promotional purposes for use on our website, social media and other marketing platforms. We will only use photos where you are the main subject with your consent.

Consent for your personal data

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. You may withdraw consent at any time by exercising your Right to Restrict Processing. Please contact us by sending an email with your request to cheltenham@freedomchurch.cc. We will comply with your request within one month of receipt and ensure that the processing activities that relied on your previously given consent will be stopped.

Special Category data you might decide to share with us

From time to time, we may collect, store and process special category data that you share with us for specific reasons. This data could include information about race, ethnic origin, politics, religion, health, sexual orientation or information about children. We will only store special category data you voluntarily share with us – and only collect, store and process this sensitive data for the purpose you allow us to do so, with your specific consent. We will restrict access to this data and minimise access as much as is possible.

Third party processors we use to process your personal data:

Any third parties we use are outlined further down in this policy, providing clear information who has access to your data for the purpose it was intended for. We have strict agreements in place with all our third-party processors in order to safeguard your data.

Data collection, storage, and email communications

We use a third-party data base provider, ChurchSuite to store and manage the vast majority of our personally identifiable information. ChurchSuite have rigorous technical and organisation data security. This means that your data is kept safely under lock and key on their UK data servers. For more information, please see the Church Suite privacy notice.

Website Hosting

We use a third-party service, Vercel, to host our website. Our website itself does not collect or store any personally identifiable information except as outlined in the ‘Visitors to our website’ section of this policy. This service meets the ISO27001 and SOC 2 Type 2 standard for data security, keeping your data safe. You can view the Vercel Privacy Policy here.

People who email us

We may also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law. Our emails are stored securely with Google Workspace, you can view their privacy policy here.

WhatsApp Communications

Due to its convenience, secure end-to-end encryption and widespread use, we use WhatsApp Business and WhatsApp community to manage the majority of our day-to- day church communications. As per the WhatsApp privacy policy your phone number may to visible to other members of the groups that you are in. If you do not want to be a part of the groups but still receive important updates from us you can subscribe to this separately and receive them as a direct message. We will never contact you via WhatsApp if you have not opted to do so and we will only do it in line with this policy. We will never add you to a WhatsApp group but always allow you to opt in. You can opt out at anytime.

SMS Communications

We may use SMS communications to send WhatsApp invitations and other transactional messages based on your preferences and consent that you have given to us. Some messages may be sent without consent such as a donation confirmation and other expected communications that are in direct response to an action that you have taken. You can opt of SMS communications at any time.

Accounting Software

We use Xero, an industry standard accounting software for book keeping and financial management. Records of your donations will be kept here. Your data is encrypted, highly secure, and protected by enterprise grade security. Access to Xero is strictly limited to essential personnel only. You can view the Xero privacy policy here.

Data Retention

We will retain your data for as long as you are donor with us or have purchased or are subscribed to one of our products or services, or have given us your consent to do so, or there is a contractual or legal obligation to do so, or where a legitimate interest exists. If none of these reasons for retention apply, then your data will be deleted from our systems after a period of time. The length of time varies depending on the nature of the data and how it was collected. For full details on Freedom Church Cheltenham’s retention policy, you can contact us at cheltenham@freedomchurch.cc

Donations and purchases

Under UK law, we have a requirement to securely hold a record of your donation or purchase for 6 years plus the current financial year.

Your rights as an individual

At any point while we are in the possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that CBN Europe refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below

Complaints or queries

We strive to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests or complaints on how we handle personal data should be sent to cheltenham@freedomchurch.cc.

Access to personal information

We try to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the GDPR. If we do hold information about you we will:

• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form.

To make a request to Freedom Church Cheltenham for any personal information we may hold, you need to put the request in writing to cheltenham@freedomchurch.cc.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone or by email.

If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting us by email.

Under the GDPR you also have the right to erasure, this means that if you would like us to delete any or all of the data we hold about you we are happy to do so. Simply put in your request to us by email.

Before we can fulfil any of the requests outlined in this section, we will need you provide sufficient evidence of your identity. Full instructions will be provided upon request.

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We are not responsible for any of the content on external sites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this privacy notice

This privacy notice is subject to change. Please check back to ensure you stay updated on how we use your data.

How to contact us

If you want to request information about our privacy policy you can email us at cheltenham@freedomchurch.cc