Our Privacy Policy

ClientEarth Privacy Notice – September 2023

ClientEarth and your personal data

ClientEarth (hereafter ‘we’ or ‘us’) take your privacy very seriously and would advise you to read this Privacy Notice closely. This Privacy Notice may change from time to time, so please check it frequently.

This Privacy Notice sets out how your personal data will be processed by us, the data controller, ClientEarth, 34 Drayton Park. London, N5 1PB. It explains your statutory rights and how we collect and use your personal data. It describes the processing activities that are carried out by us, the purposes for which these activities are performed and the legal bases that we rely upon to justify these processing activities.

ClientEarth has a number of offices around the world, some of which are separate legal entities (for example, ClientEarth US). Their use of personal data is also subject to this policy.

We collect basic personal information from visitors to this website through the use of online forms and when you email us. We may also process your personal data you provide directly to us or which we receive from our trusted partners in the charity sector.

This Privacy Policy is sets out:

If you have any queries regarding this policy or the use of your personal information, please contact our Data Protection Officer at: dataprotection@clientearth.org

There is also a separate notice on how we use Cookies.

What we use your personal data for and why

Processing your personal data is crucial for us to be able to run our campaigns, keep you informed about our activities and effectively fundraise. We appreciate the trust you place in us when giving us your personal data. The table below describes what we use different types of data for, and our legal basis for this.

Where a data category appears in italics, a glossary in the next section of this policy explains in more detail what this data category includes.

Marketing and Communications

Personal Data Used	Reason or Purpose	Legal Basis
Your contact details Your donation history Usage data Campaigns that we have determined may be of interest to you.	To send you direct marketing communications. To stay in touch with you and to invite you to give donations or otherwise contribute to our work.	Your consent in signing up to our newsletters and updates on our campaigns.
Usage data	To improve the user experience of our website and provide a better service	The legal basis for this processing is consent.
Records of your discussions with us	To keep records when you share comments and opinions with us, ask us a question or make a complaint.	Our legitimate interest in keeping records of communications.
Hashed personal information Name, email address, telephone number and postal address	To send targeted marketing through advertising on Facebook or other social media To exclude you from on-line advertising campaigns so you don’t receive information you’ve already seen To build “lookalike” audiences	Our legitimate interest in reaching people who are likely to be interested in our work more efficiently

Fundraising

Personal Data Used	Reason or Purpose	Legal Basis
Communicating with you regarding Grants and Fundraising
Your contact details Lifestyle and other demographic insight information Family members’ details Your Donation history GiftAid information	We may process your data in relation to grants and fundraising, where you donate to us or we think you may be interested in donating to us. This data may be used to contact you in relation to donations where we have an existing relationship with you.	We will process this data on the basis of your consent and/or our legitimate interest in receiving fundraising as a charity, which may include evaluating your suitability to donate to us. We may use this data to contact you in relation to donations on the basis of your consent or our legitimate interest where we have an existing relationship with you. We may also use such data for our contractual and/or legal obligations in reporting on our donations.
Prospect Research, Wealth Screening and Network Mapping
Lifestyle and other demographic insight information Published biographic information and media coverage. Previous charitable contributions.	We may use your data for Prospect Research – As a fundraising organisation, we undertake in-house research from time to time engaging with trusted third parties to gather information about you from publicly available sources, for example, Companies House and Electoral Register. This is because we rely on donations from individuals and organisations to enable us to continue our crucial work, using the power of the law to protect life on earth.	We will process this data on the basis of our legitimate interest as a charity in fundraising, which may include evaluating your suitability to donate to us.
Lifestyle and other demographic insight information Your parliamentary constituency. Estimate of the size and composition of your household. Estimate of your wealth.	We may use your data for Wealth Screening – this is a process employed to help better understand your giving capacity and whether you may be interested in providing ClientEarth additional support. We can then tailor any additional fundraising approaches to your specific circumstances and ways in which you can help support us. In order to do this, we use a trusted third party who screens a selection of records against publicly available sources (electoral register/companies house/charities commission) and/or socioeconomic data to identify those who may have an affinity to support our cause further. The third-party we work with are tied contractually to ClientEarth and are only authorised to process our data for the benefit of ClientEarth and for no other reason. We may also conduct research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. This may include people connected to our current major supporters, trustees, or other lead volunteers. We also use publicly available sources to carry out due diligence on donors in line with the charity’s Gift Aid acceptance policy to meet money laundering regulations. If you prefer us not to use your data this way, please email supportus@clientearth.org.	We will process this data on the basis of our legitimate interest as a charity in fundraising, which may include evaluating your suitability to donate to us.
Lifestyle and other demographic insight information Employment history and earnings. Published Biographic information and media coverage. Shareholdings. Philanthropic interests and networks, Previous charitable contributions and motivations	We may use your data for Network Mapping – this is where we identify individuals who may be able to give at the level of our current high-level supporters, who may be willing to develop mutually beneficial relationships and could be approached through our networks.	We will process this data on the basis of our legitimate interest as a charity in fundraising, which may include evaluating your suitability to donate to us.
Processing Online Donations
Your contact details Your charitable contributions	We may also process certain personal data in relation to donations that you make through various forms on our website, or using websites such as Rapidata to setup a regular gift.	We process this data on the basis of our legitimate interest in administering donations we receive.
Events
Your contact details	If you register for an event (in person or online) which is hosted by ClientEarth, or where ClientEarth is acting as co-host and has the responsibility of processing event participant data, to administer the event and send you communications relating to the event/s. At the point of confirming your registration via email (when relevant), we may require further information to administer the event, such as dietary requirements and any accessibility requirements.	We process this data on the basis of legitimate interest in administering the event. Receiving further information regarding dietary/accessibility requirements will be processed on the basis of your consent

Recruitment

Personal Data Used

Reason or Purpose

Legal Basis

Your contact details
Employment History
Sensitive personal data, including racial, ethnic, sexual, religious and/or disability information
Any other details in your CV.

To manage job applications.

Our legitimate interest in identifying suitable candidates for vacancies.
Sensitive personal data is only processed with your consent.

In addition to the specific purposes for which we may process your personal data set out in this table, we may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not give us any other person’s personal data, unless you are prompted to do so.

Data Categories

Your contact details: information that allows us to contact you directly in relation to our newsletter and updates, such as your full name, email address, telephone number, country and address.
Donation History: information on the transactions and donations made to ClientEarth.
Usage Data: information that allows us to see how you use the ClientEarth website or mobile applications. This includes your IP address, geographical location, browser type and version, operating system, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use.
Lifestyle and other demographic insight information: information which allows us to improve the user experience of our website, provide a better service and target our campaigns. This includes information such as marital status, gender, date of birth, dietary requirements, education and career information, areas of interest and an estimate of your assets / earnings.

Sources we collect your personal data from

We will collect personal data from a number of sources. These include:

Directly from you: when you sign up to our newsletters and updates, when you submit information through various forms on our website, when you sign up to our events or any other direct contact from you.
Our website and apps: we collect usage data about how you use our website through ClientEarth’s analytics tracking system. We also process information from any forms you full out on our website.
Third Parties:
Trusted partners: we may receive your personal data through our trusted partners where they have your consent to share your data, including the British Lung Foundation.
Publicly available third party sources: we may use data from publicly available and respected third-party sources to assess your charitable interests and as part of our fundraising activities. This includes social networks, subscription services, news archives and public databases (e.g., Companies House, property registers and the Charity Commission).

Who we share your personal data with

We share personal data with the following categories of third parties:

Who	Examples
Payment Processors in order to process your donations	When you make a donation to ClientEarth, we use third party payment service providers to handle the donation. They will collect your payment information over a secure link, protected by industry standard software. ClientEarth itself does not collect any payment information (such as payment card details) and such payment information submitted by you when making a donation is not made available to ClientEarth. Our payment service providers will use the information you provide to process your donation and will handle the information in accordance with their own privacy policies. The payment service providers we use are listed below. Click on the individual names if you’d like to read their privacy policies. Stripe  Paypal  Apple Pay  Rapidata  Online Express  CAFDonate
Marketing and Event administration when you are attending a ClientEarth event online or in person.	Blackbaud’s Raisers’ Edge Mailchimp Livestorm Zoom Eventbrite Engaging Networks
Survey providers	We may use survey providers to communicate with you or collect feedback from you. These include Mailchimp (Privacy Policy here) Blackbaud (Privacy Policy here) SurveyMonkey (Privacy Policy here) Typeform (Privacy Policy here) Engaging Networks (Privacy Policy here)
Social Media Platforms for Advertising	Facebook (they can determine whether you are a registered account holder with them and then our adverts may then appear when you access Facebook). Reddit (they can determine whether you are a registered account holder with them and then our adverts may then appear when you access Reddit). LinkedIn (they can determine whether you are a registered account holder with them and then our adverts may then appear when you access LinkedIn). Other similar social media platforms.
Campaign partners and law firms	If you have signed up to a campaign that we are running in partnership with another charity which is interested in the same issue, we may need to exchange supporter data to manage the campaign. If you sign up to participate in a campaign which involves a legal claim, we may share your information with the law firm handling the claim. We will tell you the name of the campaign partner or law firm if we are doing this. When we share data in this way, we will sign an agreement with the partner that clearly sets out their commitment to respecting your individual rights, protecting your personal data – including not using it for any purpose other than for the agreed purposes – and their commitments to assisting us to help you exercise your individual rights.
Other service providers	IT hosting and maintenance service providers These service providers are contractually required to keep your data secure and to use it only as necessary to provide the services to us. Linney - Fulfilment company we use to action the postage out of ClientEarth merchandise based on campaign activity. We securely share data as necessary to provide the services to us.

Communications, Fundraising and Online Donations

We will keep your personal data received when you sign up to our updates and information on your donations and interactions with us for the duration of your relationship with us or as long as you are in contact with us, and up to two years after. We will consider you to be in contact with us when you open our emails or take further actions through our web resources.
Financial information may be held for up to six years for legal purposes.

Pensions Campaign

We will keep data you send in relation to our Pensions campaign for the duration of the campaign and up to one year after.

Recruitment and HR

We will keep data you send us in relation to vacancies for the duration of your application and up to one year after in order to offer you new opportunities, unless you opt out of this, or extend this period with your consent. We may also hold it for longer if your application is successful.

Where we transfer and store it

Some of the service providers described or identified in section 4 above, including some of our IT service providers, are based outside the UK and European Economic Area in countries which have different data protection laws to the UK. Your information may also be accessed by campaign partners, ClientEarth offices or sister entities in other countries. Where we store or share data outside the UK and EEA, we put in place appropriate safeguards to ensure that your information and rights in respect of your information are protected. If you would like more detail about these safeguards, please contact us at info@clientearth.org.

Your Rights

You have several individual rights in relation to your personal data that we collect, which we are committed to respecting. In particular, you have the right to:

Request a copy of your personal information
Request any inaccuracies in your personal information be corrected
You may also object or ask us to restrict the processing of your personal data and have your personal information erased, where appropriate.

Additionally, where we process your personal data based on your consent, you have the right to withdraw consent at any time.

If you wish to raise a complaint on how we have handled your personal data, you can contact our office at dataprotection@clientearth.org and we will investigate the matter. You also have the right to make a complaint directly to the ICO if you wish.

Our use of Cookies

At ClientEarth, we use cookies and similar technologies:

That are strictly necessary to enable you to move around our websites or to provide certain basic features
To enhance the functionality of the website by storing your preferences
To help improve the performance of our website on your device
To understand how you interact with our website
To provide customised content and advertising ]
To show you relevant content elsewhere on the internet e.g. Facebook. This content may also include ways you can support us.

What is a cookie?

A cookie is a small text file that is downloaded onto your computer when you visit our website and allows us to recognise you as a user. Typically, these contain two pieces of information: a site name and unique user ID. All information these cookies collect is aggregated and anonymous. Cookies are essential to the effective operation of our website. Cookies make the interaction between you and the website faster and easier. Cookies may also be set by the website you are visiting (first party cookies) or they may be set by other websites who run content on the page you are viewing (third party cookies).

How can I manage cookies

We use cookies on our website. Some of these are essential to the operation of our website. You can accept or reject the non-essential cookies which we use via our Cookie Control Panel when first accessing our website. If you want to modify your choices subsequently, you can do so by accessing our Cookie Consent Notice.

Additionally, you may delete and block all cookies from any website, within your web browser settings if necessary. Please be aware that restricting or deleting cookies will impact on the functionality of the site.

You can manage the cookies stored on your device as well as stop cookies from being installed on your browser. For more information on how to manage cookies usage on your device, please let us refer you to information found on these topics on allaboutcookies.org, more specifically by clicking on the links below:

Please note that if you prefer to block some or all of the cookies ClientEarth uses, you might lose some of our website’s functionality.

You can choose to accept or opt out of cookies via our Cookie Consent Notice by clicking ‘Manage settings’.

Non-Essential Cookies

Google Analytics: analytics.js (__ga, _gat), used by Google to generate web analytics and for tracking how you use the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The information generated by the cookie will be forwarded to Google servers in the U.S. for statistical analysis purposes only.

Google Adwords: Using Google Adwords code we are able to see which pages helped to lead to contact form submissions. This allows us to make better use of our paid search budget.

Youtube/Vimeo: We embed videos from our official YouTube and Vimeo channel using a privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally – identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.

Hotjar: We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Facebook: Facebook uses cookies and other technologies to collect information on how you interact with our site. We are able to use this information to show ads and make recommendations to you if we believe you may be interested in our work or supporting our work. For more information, please see Facebook’s cookies policy by clicking here.

Pixel tags

A pixel tag is an invisible tag placed on certain pages of a website, which enables cookies to be downloaded to your browser. Pixel tags register when a particular computer and/or mobile device visits a particular page, allowing a particular user to be identified across various sites, and for targeted adverts to be served to that user across the various websites he/she visits.

Controlling pixel tags: Pixel tags are not stored on your computer or mobile device. If you disable cookies, the pixel tag will only detect an anonymous website visit.

Facebook pixel code: Facebook pixel code is a tracking pixel which matches users anonymously with their Facebook ID, enabling re-marketing, analysis, and reporting of our advertising campaigns.

For details on these cookies, please view the Facebook Cookie Policy provided at: https://www.facebook.com/policies/cookies/

Hashed lists, social media and web advertising

We may share your personal data for the purpose of targeted marketing for our campaigning and fundraising activities through Facebook advertising so that they can determine whether you are a registered account holder with them. Our adverts may then appear when you access Facebook. We may also share your personal data as part of an exclusion list for our ad campaigns, which helps us target new people for ClientEarth, rather than targeting people who have already engaged with us.

When sharing information with Facebook we will upload “hashed” personal information to Facebook Ads Manager.  Facebook then matches the hashed personal data with Facebook profiles on in their database, which will create a Lookalike audience. The process of “hashing” is commonly used in digital advertising to convert directly identifiable personal data to pseudonymous personal data for the purposes of security and privacy during data transfer. The hashed data that we share with social media platforms is deleted after between 15 mins and a few hours (subject to database size) and not used for any other purpose.

We may also use social media platform advertising tools to build audiences matching particular characteristics to serve our advertising campaigns. For example, we might target people who have shown an interest in climate change or deforestation. This targeting is based on pages and/or posts people have previously engaged with on the platform. These tools allow us to inspire new people to engage with our work, and help us spread awareness about the issues facing our planet.

If you wish to prevent this use of your data then you can adjust your settings via the social media site ( https://www.facebook.com/help/568137493302217)

The data we send could include your name, email address, telephone number and postal address.

Please note that we may share your personal data in a similar way with other social media platforms without further notification provided we assess any new online platform as having similar functioning to Facebook as well as having the required privacy standards and protocols in place to handle this data. Where the functioning of the new social media platforms or the privacy standards and protocols in place are not sufficiently similar we will notify you of any changes to our privacy policy in this respect.

Using online platforms in this way is the most efficient way for us to reach more people who are likely to take an interest in our work, meaning we use our funds most effectively.

Other Third Party Cookies

We have also included a number of features, which allow our users to share some of our content via Facebook. This does not set a cookie by itself, but if one is present it will read it. Another service we use is provided through MailChimp, which helps us to design email newsletters, share them on social networks and integrate with our other services. ClientEarth doesn’t have direct access to those cookies and the use of those third-party cookies is governed solely by the respective service provider’s Privacy statement.

Storage Time: The cookies are stored for a period of two years unless you clear their cache and the cookies themselves.

Modifications and changes to this Privacy Notice

This Privacy Notice was last updated on 17 January 2022. Any changes made to this Privacy Notice will be updated on our website and you will be notified by email if necessary and appropriate.

Change log

15 September 2023

Enhanced User-Friendly Experience: We've revamped our policy to make it more user-friendly with clearer language, headings, and easy-to-follow links. We've also included examples to better illustrate our activities.
Transparency on Data Integration: We provide more details on how we integrate our systems and share information. This includes improvements to our internal processes, making them more personalised, intelligent, and integrated with other systems that may use your data. The revised policy also explains when and why ClientEarth shares data with third parties.
Empowering Users: We empower you to manage the information you share with us. Our updated cookies statement and cookie control centre reflect this commitment. The policy outlines how you can exercise your choices regarding your information and highlights the security measures we've implemented to protect your data.
Inclusivity and Personalisation: We've removed the previous threshold for wealth screening, aiming for greater inclusivity. This helps us better understand your philanthropic potential and your willingness to provide further support. This strategic refinement enables us to tailor our communications to your unique situation, offering meaningful ways for you to impact our initiatives. This, in turn, allows us to take on more vital work worldwide and increase our overall impact.

17 January 2022:

Added additional section on events

10 December 2021:

Added additional information prospect research, wealth screening and network mapping

5 Aug 2021:

Added additional information on use of Facebook Pixels, hashed lists and Facebook advertising

7 June 2021:

Changed ClientEarth address from Fieldworks, 274 Richmond Road, London E8 3QW to: 34 Drayton Park, London, N5 1PB

6 June 2020:

Added information on use of Typeform and SurveyMonkey
Added information on how and why we process data as part of the Pensions Campaign

12 November 2019:

Added information on use of Facebook pixel
Updated subscriber reconsent conditions
Added information about payment processors (Stripe, Rapidata)

Previous versions of privacy policy

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