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BYELAW 13  |  PRIVACY POLICY 

1. WHO WE ARE 

YesCymru Cyf is a non-party political grassroots organisation campaigning for Welsh independence, majority funded by Member subscriptions and donations. The only other income comes from the sale of YesCymru Cyf merchandise in the YesCymru online shop (see Section 5). YesCymru is committed to maintaining the trust and confidence of all supporters, whether a visitor to the website, a Member or someone who has shown an interest by asking to receive the newsletter. 

YesCymru Cyf values everyone’s support in the campaign to achieve independence for Wales. We will only collect the minimum personal data needed in order to keep subscribers up to date with campaigns and to enable them to get more involved if they want to. 

2. VISITORS TO OUR WEBSITE 

When someone visits yes.cymru it uses a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. YesCymru Cyf does this to find out things such as the number of visitors to the various parts of the site. This information is processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. 

3. MEMBERS 

As part of the joining process for YesCymru Cyf, we collect the minimum personal information that is needed to process payments – name, postal address, email address, as well as payment details (see below). This is used to keep people up to date with our news and campaigns (so that Members know what membership payments are helping us to achieve) and ways that Members can get more involved. The main way that we keep Members informed is via our mailing list. We will automatically add Members to this when they join YesCymru Cyf. Anyone can unsubscribe at any time (see Section 7). 

Members on an annual subscription will be contacted by email when their membership is due for renewal. Members making monthly payments will be 

contacted if there are any interruptions in payments (which usually happens because a bank card has been renewed or cancelled). 

Members of YesCymru Cyf, will be automatically added to our "Say Yes" pledge (see Section 4). 

When Members voluntarily share personal or special category information with YesCymru Cyf, it is taken that shared information may be used to assist Members or otherwise to achieve our aims and objectives. 

We may process personal data in order to investigate and handle internal complaints. 

3.1 Joining via our website 

When joining via the website, payment will need to be set up using a debit or credit card. This is handled by the NationBuilder payment processor. YesCymru Cyf does not collect or store any card details. In addition to the personal information collected as described at the beginning of Section 3, YesCymru Cyf needs phone numbers because this is a requirement of the payment processor to initiate the payment. 

3.2 Joining via a paper form 

In order to set up a standing order, details of a Member’s bank account will be collected. We transfer other details from the form onto our membership database, then send the paper form directly to the Member’s bank. We will not store any Member’s bank details. 

4. OUR “SAY YES” PLEDGE 

The data collected in order to process Members’ signatures is their name, email address, and postal address. We require postal addresses to enable us to find and remove duplicate entries, to ensure the integrity of the petition. 

4.1 Signing via our website 

Signing the petition on our website is a commitment to voting "Yes" in a referendum on Welsh independence. On that basis, our reasonable belief is that it is within the signatory’s legitimate interests and our legitimate interests, that we add those people to our mailing list so that they can hear more about the work of YesCymru Cyf. 

4.2 Signing via YesCymru Cyf membership 

Members of YesCymru Cyf do not need to fill in their details again for the petition, as this will happen automatically when they join. 

4.3 Signing via a Facebook Ad 

Apart from our website, the petition can be signed by submitting a Lead Ad form that is published via our Facebook page. Facebook will pre-populate details, but these can be modified before sending. These details will then be sent to the NationBuilder system and added to YesCymru’s mailing list. Use of Lead Ads is in accordance with Facebook’s Data Policy. 

5. CUSTOMERS IN OUR ONLINE SHOP 

We collect information about customers when they use the online shop, in order to process the order. We only collect the information we need, which will be the customers’ name and postal address (so that we can send the goods to the customer) and an email and telephone number (so that we can contact them easily if there is a problem with the order). This information will be held on the Ecwid database (view the Ecwid privacy policy), so that customers don’t have to re-register with us each time for future purchases. We will not use contact details to contact customers about anything other than their purchase, unless they opt in to receive more information from us during Checkout, in which case we will add them to our mailing list (see Section 7). 

6. OTHER WAYS OF CONTACTING US 

If customers get in touch with us via post or email about any other matter (or send us contact details via social media, or for example, by direct message on Twitter), and are not already a Member or a subscriber to our newsletter, we will not contact them about any matter other than the topic they have originally contacted us about. 

If we meet (for example at an event) and contact details are given to us in order to keep in touch, we will only collect name and email address, and will seek permission to add the contact to our mailing list. Contacts regarding a specific issue will not be added to our mailing list. 

7. OUR MAILING LIST 

We use a third party provider, NationBuilder, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletter. For more information, please see NationBuilder's privacy notice. 

We may use third party survey software, 123FormBuilder, to send surveys, where we collect the same personal information described in Section 3. The data is securely stored by 123FormBuilder. For more information, please see 123FormBuilder's privacy notice. 

The different ways to subscribe to our mailing list are explained above. Subscribers will receive occasional newsletters to keep them up to date with news, campaigns, events and ways they can get involved. These emails may be sent from YesCymru Cyf centrally, or from the local YesCymru Cyf group (see Section 8). 

We may also use contact information to check that our records are accurate and to check every now and then that contacts are happy and satisfied. 

From time to time, we may provide information about specific appeals we are running, for example if we are crowdfunding to raise money for a campaign, but we will keep these communications to a minimum. 

We may also partner with various local independence-supporting businesses around Wales that have committed to offering discounts on their goods and services exclusively to Members of YesCymru Cyf. We may email about these offers from time to time. YesCymru Cyf does not share any Member/contact details with these companies. 

Apart from the subscription methods described above, the website may be used to subscribe to our mailing list via the Sign up for news and updates section of our website. As part of the registration process for our mailing list, we collect minimum personal information - name and email address. 

7.1 Unsubscribing from our mailing list 

People on our mailing list may unsubscribe at any time by clicking the To change your email preferences, click here link at the bottom of any of our emails. There will be an option of whether to unsubscribe from specific types of email, or from all emails. The specific types of emails that can be unsubscribed are:- news and updates from YesCymru Cyf centrally, news and updates from YesCymru Cyf groups, and emails from YesCymru Cyf centrally containing exclusive offers from our partners. 

People may also unsubscribe by emailing us at [email protected]. If contacts unsubscribe via this method, we assume that they want to unsubscribe from all types of email, unless they state otherwise. 

8. SHARING INFORMATION WITH GEOGRAPHIC GROUPS 

YesCymru Cyf has a number of Geographic Groups operating in different communities across Wales. Members will be added to their local Geographic Group’s mailing lists automatically. A Group is deemed to be local if the Member lives in a county council ward deemed to be within the group’s catchment area - usually within a 10 mile radius of a Group. The ward is approximated by geocoding, which requires all parts of the postal address, and is based on the most recent address we hold for that person. 

The Geographic Group is bound by the privacy policies set out in this document. Provided that the Geographic Group also satisfies the criteria set out in Byelaw 7.5, the Group may nominate a person or persons to act as Data Processors. The Data Processor(s) for Geographic Groups may contact Members via email on behalf of their Group. They will only use Members data to keep them up to date with news about what the group is doing, and to issue invitations to local events and meetings. The Data Processor(s) for the Group will not be permitted to export data from our database, or share it with any third parties. 

Individual’s data will not be visible to the Data Processor(s) of any other YesCymru Cyf Group. 

All Data Processors for YesCymru Cyf are bound by the YesCymru Cyf Data Protection Declaration (Byelaw 12). 

Members can unsubscribe from the mailing list of their Geographic Group at any time by selecting the relevant option within the To change your email preferences, click here link at the bottom of any email from YesCymru Cyf or a Geographic Group (see Section 7.1). 

9. GENERAL 

We are a not-for-profit organisation that qualifies for an ICO registration fee exemption, and we are not legally required to appoint a data protection officer. 

We do not rent or trade email lists with any other organisations or businesses. We process personal data under the legal basis of Legitimate Interest. 

We will retain the personal information that we collect from Members until one year following the expiry of their membership. 

We do not use automated decision-making or profiling as part of our data processing activities. 

Individuals have the following rights in relation to their personal data: 

  • To be informed about the data we hold, and how and why we process it; 
  • To request a copy of the personal information that we hold about them; 
  • To require us to rectify any inaccuracies within the personal data we hold about them; 
  • To restrict processing of their data, if data is inaccurate or being processed unlawfully; 
  • To object to their data being processed if they suspect that what we are doing is not legitimate; 
  • To request that their data is deleted; 
  • To request that we send a copy of their data electronically to them, or to a third party; 
  • To withdraw consent by unsubscribing to our newsletter or cancelling a membership; 
  • To lodge a complaint with the Information Commissioner's Office (ICO), who is our supervisory authority for data protection (https://ico.org.uk/concerns). 
10. FURTHER INFORMATION 

Any questions about this privacy statement or about how we use or store data? Contact us at [email protected]. 

Our registered address is:- YesCymru Cyf, Office 23609, PO Box 92, Cardiff, CF11 1NB.