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Registered charity in England and Wales (1106885).
Registered office: C/O Tgw Law, 4 Hill Street, London, England, W1J 5NE.
A company limited by guarantee, registered in England and Wales company number 04988238.
Privacy Policy Background:
Khodorkovsky Foundation understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, http://khodorkovskyfoundation.org/ (“Our Site”) and/or has involvement with Us and We will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Use of Our Site is subject to the terms of this Privacy Policy. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
In this Policy, the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 15 below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) and the Data Protection Act 2018 (together, the “Data Protection Legislation”).
“We/Us/Our” means Khodorkovsky Foundation.
2.1 Our Site is owned and operated by Khodorkovsky Foundation, a registered charity in England and Wales (1106885). Registered office: C/O Tgw Law, 4 Hill Street, London, England, W1J 5NE. A company limited by guarantee, registered in England and Wales company number 04988238.
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4.1 As a data subject, you have the following rights under the Data Protection Legislation, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
5.1 IP address
5.2 Web browser type and version
5.3 Operating system
5.4 URLs starting with a referring site, your activity on Our Site, and the site you exit to
5.5 Usage information: Information about the actions that site users perform on a site, in other words, who did what, when and to what on a site.
5.6 Information from cookies and other technologies
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your access to Our Site;
6.2.2 Market research;
6.2.3 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 Information from Cookies and other technologies: a cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We use cookies to help identify and track anonymous users.
6.4 Third parties whose content appears on Our Site may use third party Cookies, as detailed below. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 We may disclose information about you to independent contractors that need to know the information in order to help us provide our services or to process information on our behalf. We require our independent contractors to follow this privacy policy for personal information that we share with them.
6.6 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.7 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored in the UK.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Encrypting communication between users and our servers by enforcing SSL
7.4.2 Encrypt sensitive data such as communication between users at rest
7.4.3 Apply proactive security best practices
8.1 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.2 Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information) and those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them.
8.3. Independent contractors: We may disclose information about you to our independent contractors that need to know the information in order to help us provide our services or to process the information on our behalf. We require our independent contractors to follow this Privacy Policy for personal information we share with them.
8.4 We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorise us to do so.
9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10.1 In addition to your rights under the Data Protection Legislation, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes.
11.1 You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required approve the collection of certain data.
11.2 You may restrict Our use of Cookies.
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at atulloch@tgwlaw.co.uk, or using the contact details below in section
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at atulloch@tgwlaw.co.uk or by post at Khodorkovsky Foundation, C/O Tgw Law, 4 Hill Street, London, England, W1J 5NE.
Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 7, above).
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
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As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others.
The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.
Tel: 020 73181180
Email: atulloch@atulloch.com
4 Hill Street, London W1J 5NE