1. Introduction

The Alice Ruggles Trust is committed to safeguarding the privacy of personal data. This privacy policy aims to inform you of the nature, scope, and purpose of the personal data that we may collect, use and process, and of your legal rights in regard to these data.

We the Alice Ruggles Trust have implemented various technical and organisational measures to ensure the most complete protection of personal data processed through our website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, you are free to transfer personal data to us via alternative means.

2. Definitions

The following data protection declaration of the Alice Ruggles Trust is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). In this data protection declaration, we therefore use, inter alia, the following terms:

  • a)    Personal data

    Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • b) Data subject

    A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

  • c)    Processing

    Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • d)    Restriction of processing

    Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

  • e)    Profiling

    Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

  • f)    Controller or controller responsible for the processing

    The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.

  • g)    Processor

    The processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  • h)      Recipient

    A recipient is a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

  • j)      Third party

    A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

  • k)    Consent

    The consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes whereby s/he, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him- or herself.

The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in member states of the European Union and other provisions related to data protection is the Alice Ruggles Trust, a charity registered with the Charity Commission of England and Wales (registered charity number 1175316). The controller can be contacted by email at info @ alicerugglestrust.org.

3. Collection of general data and information

The website of the Alice Ruggles Trust collects a series of general data and information when a data subject or automated system calls up the website. These general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Alice Ruggles Trust does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Alice Ruggles Trust analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

4. Routine erasure and blocking of personal data

The Alice Ruggles Trust, as data controller, will process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the Trust is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

5. Your rights as data subject

  • a) Right of confirmation

    You have the right granted by the European legislator to obtain from the Alice Ruggles Trust, as controller, a confirmation as to whether or not personal data concerning yourself are being processed. If you wish to avail yourself of this right of confirmation, you may contact the Trust at any time.

  • b) Right of access

    You have the right granted by the European legislator to obtain from the Alice Ruggles Trust, as controller, free information about your personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

    • the purposes of the processing;
    • the categories of personal data concerned;
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
    • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • the existence of the right to request rectification or erasure of personal data concerning yourself, or restriction of processing of personal data concerning yourself, or to object to such processing;
    • the existence of the right to lodge a complaint with a supervisory authority;
    • where the personal data were not collected from you, any available information as to their source;
    • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for yourself [however, see §14 below].

    Furthermore, you have a right to obtain information as to whether personal data relating to yourself are transferred to a third country or to an international organisation. Where this is the case, you have the right to be informed of the appropriate safeguards relating to the transfer. If you wish to avail yourself of this right of access, you may contact the Trust at any time.

  • c) Right to rectification

    You have the right granted by the European legislator to obtain from the Alice Ruggles Trust, as controller, without undue delay the rectification of inaccurate personal data concerning yourself. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may contact the Trust at any time.

  • d) Right to erasure (Right to be forgotten)

    You have the right granted by the European legislator to obtain from the Alice Ruggles Trust, as controller, without undue delay the erasure of personal data concerning yourself. The Trust also has the obligation to erase personal data without undue delay where one of the following grounds applies, as long as processing is not necessary:

    • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
    • you withdraw the consent upon which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there are no other legal grounds for the processing;
    • you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR;
    • the personal data have been unlawfully processed;
    • the personal data must be erased for compliance with a legal obligation in European Union or Member State law to which the controller is subject; or
    • the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

    If one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by the Alice Ruggles Trust, you may contact the Trust at any time. The Alice Ruggles Trust will ensure that the erasure request is complied with promptly. Where the Trust has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the Alice Ruggles Trust as controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that you, the data subject, have requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Alice Ruggles Trust will arrange the necessary measures in individual cases.

  • e) Right of restriction of processing

    You have the right granted by the European legislator to obtain from the Alice Ruggles Trust, as controller, restriction of processing where one of the following applies:

    • you contest the accuracy of the personal data, for a period enabling the Trust to verify the accuracy of the personal data;
    • the processing is unlawful but you oppose the erasure of the personal data and request instead the restriction of their use;
    • the Alice Ruggles Trust no longer needs the personal data for the purposes of processing, but they are required by you for the establishment, exercise or defence of legal claims; or
    • you have objected to processing pursuant to Article 21(1) of the GDPR pending the verification of whether the legitimate grounds of the Trust override those of you as the data subject.

    If one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by the Alice Ruggles Trust, you may contact the Trust at any time. The Alice Ruggles Trust will arrange the restriction of the processing.

  • f) Right to data portability

    You have the right granted by the European legislator to receive the personal data concerning yourself that was provided to the Alice Ruggles Trust, as controller, in a structured, commonly used and machine-readable format. You have the right to transmit those data to another controller without hindrance from the Alice Ruggles Trust, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Alice Ruggles Trust.

    Furthermore, in exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have personal data transmitted directly from one controller to another, where it is technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, you may contact the Alice Ruggles Trust at any time.

  • g) Right to object

    You have the right granted by the European legislator to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning yourself which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions [however, see §14 below]. The Alice Ruggles Trust will no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

    If the Alice Ruggles Trust processes personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning yourself for such marketing. This applies to profiling to the extent that it is related to such direct marketing [however, see §14 below]. If you object to the Alice Ruggles Trust to the processing for direct marketing purposes, we will no longer process the personal data for these purposes.

    In addition, you have the right, on grounds relating to your particular situation, to object to the processing of personal data concerning yourself by the Alice Ruggles Trust for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

    In order to exercise the right to object, you may contact the Alice Ruggles Trust at any time. You are also free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use your right to object by automated means using technical specifications.

  • h) Automated individual decision-making, including profiling

    You have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning yourself, or similarly significantly affects yourself, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between you and a data controller, or (2) is not authorised by European Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.

    If the decision (1) is necessary for entering into, or the performance of, a contract between you and the Alice Ruggles Trust, as data controller, or (2) it is based on your explicit consent, the Alice Ruggles Trust shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Trust to express your point of view and contest the decision.

    If you wish to exercise your rights concerning automated individual decision-making, you may contact the Alice Ruggles Trust at any time.

  • j) Right to withdraw data protection consent

    You have the right granted by the European legislator to withdraw your consent to the processing of your personal data at any time. If you wish to exercise your right to withdraw the consent, you may contact the Alice Ruggles Trust at any time.

6. Data protection provisions about the application and use of Facebook

On the Alice Ruggles Trust website, we have integrated components of the social network Facebook.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of the Trust’s website into which a Facebook component (Facebook plug-in) has been integrated, the web browser on your information technology system is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed at https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by you.

If you are logged in at the same time on Facebook, Facebook detects with every call-up to our website by yourself—and for the entire duration of your stay on our Internet site—which specific sub-site of our Internet page was visited by you. This information is collected through the Facebook component and associated with your Facebook account. If you click on one of the Facebook buttons integrated into our website, or if you submit a comment, then Facebook matches this information with your personal Facebook user account and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by yourself, whenever you are logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether you click on the Facebook component or not. If such a transmission of information to Facebook is not desirable for you, then you may prevent this by logging off from your Facebook account before calling up our website.

The data protection guidelines published by Facebook, which are available at https://facebook.com/about/privacy/, provide information about the collection, processing and use of personal data by Facebook. These guidelines also explain the setting options Facebook offers in order to protect your privacy. In addition, different configuration options are made available to permit the elimination of data transmission to Facebook. You can use these applications to eliminate a data transmission to Facebook.

7. Data protection provisions about the application and use of Twitter

On the Alice Ruggles Trust website, we have integrated components of Twitter. Twitter is a multilingual, publicly accessible microblogging service on which users may publish and spread so-called ‘tweets’, i.e. short messages that are limited to 280 characters. These short messages are available to everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called ‘followers’ of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows its users to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

With each call-up to one of the individual pages of the Trust’s website on which a Twitter component (Twitter button) has been integrated, the Internet browser on your information technology system is automatically prompted to download a display of the corresponding Twitter component. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by you. The purpose of the integration of the Twitter component is a retransmission of the contents of our website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If you are logged in at the same time on Twitter, Twitter detects with every call-up to our website by you and for the entire duration of your stay on our Internet site which specific sub-page of our Internet page was visited by you. This information is collected through the Twitter component and associated with your Twitter account. If you click on one of the Twitter buttons integrated on our website, then Twitter assigns this information to your personal Twitter user account and stores the personal data.

Twitter receives information via the Twitter component that you have visited our website, provided that you are logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether you click on the Twitter component or not. If such a transmission of information to Twitter is not desirable, then you may prevent this by logging off from your Twitter account before calling up our website.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

8. Payment method: data protection provisions about the use of PayPal as a payment processor

On the Alice Ruggles Trust website, we have integrated components of PayPal. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal is also able to process virtual payments through credit cards when a user does not have a PayPal account. A PayPal account is managed via an e-mail address, which is why there are no classic account numbers. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

If you choose "PayPal" as the payment option when donating to our charity, we automatically transfer you to PayPal. Your personal information is then handled by PayPal in accordance with their own privacy policy and data protection provisions, which may be retrieved at https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

When a donation to the Alice Ruggles Trust is handled by PayPal, they pass us the information necessary to administer your donation and verify your identity. By selecting this payment option, you agree to the transfer of these personal data.

9. Payment method: data protection provisions about the use of MyDonate as a payment processor

On the Alice Ruggles Trust website, we have links to MyDonate. MyDonate is a no-commission, online fundraising service operated by British Telecommunications plc (“BT”) for UK based charities to raise money using BT’s own end-to-end payment processing system. The service includes the operation of the MyDonate website, the collection of charity donations, management of the collection of Gift Aid from HMRC, and transfer of funds via BACS to the charity’s designated bank account.

When you follow one of these links, your personal information will be handled by MyDonate in accordance with their own privacy policy, which may be retrieved under https://www.btplc.com/mydonate/aboutmydonate/Privacypolicy/index.aspx.

When a donation to the Alice Ruggles Trust is handled by MyDonate, they pass us the information necessary to administer your donation. If you make an anonymous donation, without registering with MyDonate, they still need to collect your name and address to verify your identity and will still pass these details to us so that we can verify your identity.

10. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject (not in this case a donor) is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations as are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. If our charity is subject to a legal obligation by which the processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary in order to protect the vital interests of a data subject or those of someone else (another “natural person”). This would be the case, for example, if a visitor were injured and their name, age, health insurance data or other vital information needed to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our charity or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

11. Legitimate interests pursued by the Alice Ruggles Trust or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our charitable activities in favour of the well-being of all our stakeholders.

12. Period for which the personal data will be stored

The criterion used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data are routinely deleted, as long as it they are longer necessary for the fulfilment of the contract or the initiation of a contract.

13. Provision of personal data as statutory or contractual requirement; requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

The provision of personal data could be partly required by law (e.g. tax regulations) or could result from contractual provisions (e.g. information on the contractual partner). In some circumstances it could be necessary, in order to conclude a contract, for such a partner to provide us with personal data which would subsequently need to be processed by us. A data subject might, for example, be obliged to provide us with personal data when our charity signs a contract with them. The non-provision of the personal data would have the consequence that the contract could not be concluded. Before personal data is provided by a data subject, the Alice Ruggles Trust will clarify with them whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.

14. Existence of automated decision-making

As a responsible charity, we do not use automatic decision-making or profiling.


This Privacy Policy is based upon a draft generated by the Privacy Policy Generator of the German Association for Data Protection that was developed in cooperation with Privacy Lawyers from Wilde Beuger Solmecke, Köln, Germany.