Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE YOUNG-MONEY.ORG.UK WEBSITE, PARTICIPATING IN OUR YOUNG MONEY CHALLENGES OR DOWNLOADING ANY YOUNG MONEY RESOURCES

LAST UPDATED: [April 2018]

1. Overview
Young Money is a trusted and valued provider of knowledge, resources and training to anyone teaching young people how to manage money.

If you are browsing or logging on to https://www.young-money.org.uk (our "Website") or using our Young Money support services or resources (our "Services") or participating in any way in any Young Money activities, projects, programmes, campaigns or challenges (our "Activities") including by submitting hard copy entry forms then this privacy policy (the "Policy") applies to you.

The Website is provided by Young Enterprise. If we refer to "we", "us" or "our" in this policy, we mean Young Enterprise.  There is more information about us at section 12 (at the bottom of this Policy).

Please read this Policy carefully as it explains how we collect and use information about you and the young people you work with ("personal information"), what we do with that personal information, who we share it with (and why), where it may be processed and the choices we provide to allow people to control, access and update that personal information.
We also have a separate Cookies Policy which explains how and why we use cookies on our Website. Our Cookies Policy can be found here and further information about cookies (what they are and how they are used by us and others to collect personal information about you) is in section 10 of this Policy.

2. What information do we collect about you and/or the young people you work with and how is it collected?
When you use our Website and Services or you participate in any of our Activities, you are in control of how much personal information you choose to give us about yourself and others.  There are two ways that we collect personal information.  These are direct collection of information and indirect collection of information. Directly collected information is information you have submitted to us yourself. Indirectly collected information is information that you do not provide to us but which we have collected by other means.

The information that you might provide to us could include, for example, your name, email address, telephone number, name of the school or college you are associated with and the names, ages and year groups of the young people you work with.

Information provided to us: You may, for example, provide personal information to us about yourself and the young people you are working with when you:
• register your details and/or register the young people to participate in our Activities or use our Website or our Services;
• fill in hard copy Teacher Entry and Young People Entry forms;
• send us copies of the work which the young people have created;
• report a problem with our Website or Services or ask a question in respect of our Activities;
• enter any of our competitions;
• share information via our Website or social media functions (such as your social media profiles);
• contact us (for example, by telephone or email);
• give us feedback; or
• complete a survey.

You may choose whether or not to give some information to us. However, not providing certain information may mean you cannot enjoy all or parts of our Website or Services and affect your or the young people’s participation in our Activities.

Information that is automatically collected: When you use our Website, we automatically record information about your visit from your web browser or the device you are using to access the Website (such as your phone, laptop or home computer). The information that might be automatically collected in this way includes:
• the IP address of your device, device information such as whether it is a phone or laptop, the unique device identifier (which is a specific number that your devices will have) and the software your device is using;
• how you use our Website such as what pages you look at and how long you are on a Website page;
• website traffic data;
• cookie information (as explained in our Cookies Policy); and
• location information (e.g. what country or city you are in when you access our Website but this information is only seen by us if your device settings allow this).
Some of this information may be collected automatically using cookies and similar tracking technology, as explained further at section 10 of this Policy.

3. How do we use the personal information we collect?
The personal information you provide to us (directly and also indirectly as explained at section 2 of this Policy) is used for the following reasons:
• To carry out our commitments to you, including:
o processing your request to receive our termly e-newsletter, download our Resources or your application for you and your young people to participate in our Services and Activities;
o operating and administering your participation or other involvement in our Activities;
o providing you with our Website, Services and Resources;
o running any Young Money competitions which you or the young people choose to enter including our My Money Week competition;
o sharing your information with any consultants who we engage to help delivery our Activities to you and the young people.
• To manage your and the young people’s involvement in our Activities and your Website account (where you register to participate in our Activities on our Website) and respond to questions you have for us about our Activities, Resources, or our Website or Services (such as technical issues you might be having or a request to reset your password);
• To tell you about our Activities, our Services and any changes or updates to our Activities or to our Services;
• To promote Young Money and our Activities and any other of our products, services programmes or events which we think you may be interested in, but we will only do this if you have given us your permission to contact you for these reasons or if the law allows us to do so;
• To answer your questions about our Activities, our Website and our Services;
• To verify your identity and account information so we can guard against anyone trying to access your account without your permission;
• To improve the products, Activities and Services which we can offer to you (and others);
• To deal with and respond to any complaints, questions or feedback which you (and others) provide about our Activities, our Website or Services;
• To improve the operation of the Website (such as how it looks, how well it works and what information you see on the Website);
• To conduct surveys and to obtain your feedback on our Activities, Website and our Services and other questions or issues which are relevant to Young Money;
• Where any of our Activities in which you or your young people participate are funded by another organisation, to provide updates and reports on those Activities to our funders;
• To make our Website work well when you access it from different devices such as your phone or laptop;
• To prevent, monitor and take action in respect of any suspected or reported fraudulent or illegal activity; or
• To report any incidents or claims to our insurers.

We may also use information which you have provided or which has automatically been collected from you in an anonymised way. This means that we cannot link the information to you or the young people and have no way of knowing who the information is about. We use anonymised information for these reasons:
• For analysis, research and statistical purposes to help us understand who is participating in our Activities and to provide reports and updates to the funders of our Activities at an aggregated level), using the Website and Services and when and how they are used. For example, the type of anonymised information we might use includes:
o the number of participants/teams from the same organisation, in the same region and age-groups of participants;
o  the number of attempts made to complete and/or actual completion rates of exercises available through the Website; and
o the written words and phrases used by people taking part in our Activities so that we can try to discover themes and patterns in those written responses.
• To maintain, protect and improve the Website, our Services and our Activities by, for example:
o Presenting information to our leadership team about our Activities and the people and organisations that take part in them;
o Promoting communications about our Website and our Activities within YE and externally to the organisation (but we will not provide personal information to third parties so that they may promote their products and services to you, unless you have provided your permission for us to do this);
o Lobbying to inform the government and funding bodies of demand for our Resources and Activities to try to get more support; and
o To understand the education and work goals and achievements of the people using our Resources and taking party in our Activities.

4. Legal basis for processing personal information
We will normally collect personal information about you and the young people from you only where:
• we have the relevant person's permission (or that of their parent or guardian);
• we need the personal information to perform a contract with the relevant person; or
• it is in our legitimate interests and not overridden by the data protection interests or fundamental rights and freedoms of the relevant person.
If we ask you to provide personal information that is needed by law or to perform a contact, we will tell you at the time and also tell you whether you are able to proceed without providing personal information.
Where we collect and use personal information on the basis of our legitimate interests (or those of any other group), our legitimate interests include the activities in section 3 above.  If we process personal information for any other legitimate interests, we will tell you at the time what those legitimate interests are.
If you have questions about or need more information about the legal basis on which we collect and use personal information, please contact us using the contact details provided at section 11 below.

5. Who do we share personal information with?
We may share personal information with the following people and organisations:
• Companies in our Group, including Young Enterprise Scotland (for further details, please visit:  http://www.yes.org.uk/, Young Enterprise Northern Ireland (for further details, please visit: http://www.yeni.co.uk/ and Young Enterprise Gibraltar whose details can be found on our website;
• Our partners, being those companies that we engage to provide services for us in respect of the Website, Services and our Activities which are:
o  Prolog, who collate the information that you provide in order to send Resources to you;
o IE Digital, who support, maintain and host the Website;
o MailChimp (operated by The Rocket Science Group LLC), who provide mailing services to us so that we can send e-mail communications to you about our Activities; and
o SurveyMonkey Inc. who provide us with online survey services in respect of our Activities.
• Our funders, being any organisation which provides funding for our Activities, our Services and our Resources;
• The police, local authorities, Her Majesty’s Revenue and Customs (HMRC), the courts and any other government authority where we believe the sharing of your information is necessary:
o by law;
o for us to exercise, establish or defend our legal rights; or
o to protect a person's vital interests.
• Our professional advisors including our lawyers and accountants when they need it to give us their professional advice;

• Our insurers where it is necessary to disclose personal information in respect of a claim under our insurance; or

• In the event that we sell or buy our business or property, in which case we will share personal information with the seller or buyer of the business or property.
Where we share personal information with these people and organisations, we will only do so for the purposes set out above and as specified in section 3.

6. International transfers of personal information
Personal information may be transferred to, and processed in, countries other than where the relevant person lives. Those countries may have data protection laws that are different to the laws of that person's country (and may not be as protective).

We process personal information in the United Kingdom [and the Republic of Ireland] and some of our service providers will process personal information in the United States. 
IE Digital processes personal information in order to support and maintain the correct operation of our Website, and their contractual obligations to Young Money. The Website is hosted is the EU.

Prolog process personal information to send our Resources and your personal information will only be processed in the United Kingdom.
Where we use personal information to send e-mails to you using the 'MailChimp' service, 'MailChimp's' servers are located in the United States.
Where we send you surveys/feedback requests in relation to our Activities or our Website or Services and you respond to these, personal information will be processed by 'SurveyMonkey' whose servers are located in the United States.
The companies who operate the 'MailChimp' and 'SurveyMonkey' services are located in the United States and both companies participate in and have certified their compliance with the EU - US Privacy Shield Framework.  You can find more information about how these companies will process personal information by reading their privacy policies at https://mailchimp.com/legal/privacy/ and https://www.surveymonkey.com/mp/policy/privacy-policy/ and you can read more about the EU – US Privacy Shield Framework at https://www.privacyshield.gov/list
We have taken steps to make sure that personal information is protected in line with this Policy where it is processed by us or shared between our group companies and we require all group companies to protect personal information they process about individuals in the EEA in accordance with European Union data protection law.

7. How long do we keep personal information?
We retain personal information we collect from you where we have an ongoing organisational need to do so (for example, to provide you with a service you have requested or to comply with the law or tax or accounting requirements or to deal with any claim which you, we or somebody else may have in respect of personal information).
When we no longer have an organisational need to process personal information, we will either delete or anonymise it or, if this is not possible (for example, because the personal information has been stored in backup archives), then we will securely store the personal information and make sure that it is not processed until we can delete it.

8. Your rights
You and the young people have the following data protection rights:
• If you or a young person wishes to access, correct, update or request deletion of personal information, you can do so at any time by contacting us using the contact details at section 11 below. You may also be able to do this within your secure account. Please note that some information cannot be changed once you have entered it. This is to discourage users from engaging in unlawful activities. We may be unable to continue providing our Website or Services or continue to allow you or the young people to participate in our Activities if you delete certain pieces of personal information we hold– if you have any questions or concerns about this, please get in touch with us (our contact details are in section 11).
• You and the young people can also object to processing of personal information, ask us to restrict processing of personal information or request portability of personal information. Again, these rights can be exercised by contacting us using the contact details at section 11 below.
• You and the young people have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details at section 11 below.
• If we have collected and processed personal information on the basis of consent, then that consent can be withdrawn at any time but we may still be entitled to use the information on a different legal basis.
• You and the young people have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. In the UK this will be the Information Commissioner’s Office (the "ICO"). The ICO makes a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers, such as Young Enterprise, are available publicly. You can access them at www.ico.org.uk. 
We answer all requests from people wanting to exercise their data protection rights in line with the requirements of data protection laws.
 

9. Updates to this Policy
Over time we might change the personal information we collect, how we store it, who we share it with and how we use it.
We may need to update or change this Policy from time to time. We will try our best to tell you about any changes by posting on the Website or the Young Enterprise website www.young-enterprise.org.uk and will ask for your permission where the changes are important and where your (or the young people's) permission is required under data protection law. That way, you can check to see if you’re still happy.

10. Cookies
We use cookies to help us to provide you with a good experience when you use our Website and improve our Website (for example, to remember you when you come back and visit our Website, if you want us to, and also to provide us with information about the performance of our Website and the number of people who use our Website, where they are located, when they access our Website and how long they spend on our Website). For more information on the cookies we use and the purposes for which we use them, see the Young Money Cookie Policy which can be found here
 

11. Contact us
Please contact us if you have any questions about information we hold about you or about this Policy:
• Send an email to info@y-e.org.uk
• Write to us at FAO: DCEO, Young Enterprise, Peterley House, Peterley Road, Oxford OX4 2TZ United Kingdom.

12. About us
Young Enterprise is a charity incorporated in England and Wales as a company limited by guarantee, with company number 712260 and registered charity number 313697 and having its registered office at Yeoman House, Sekforde Street, London, EC1R 0HF.

We are the ‘data controller’ for the personal information that we process in accordance with this Policy. This term is a legal phrase used to describe a person or entity that controls the way someone's personal information is used and processed.

We are registered with the Information Commissioner’s Office in the United Kingdom. Our registration number is Z6643877.