Privacy Policy

This Privacy Policy explains how Stewards Of Tomorrow Ltd (“Legacy”, “we”, “us” or “our”) collects, uses, shares and protects your personal information when you:

• use the Legacy app;
• visit givewithlegacy.com and our other websites;
• create a Care Page with Share To Care, or give through one; or
• join a waiting list, contact our support team, or deal with us in any other way.

We are the controller of your personal information. We are a non-profit company limited by guarantee, registered in England and Wales (company number 15589404), with our registered office at C/O West & Berry Limited, Nile House, Nile Street, Brighton, BN1 1HW, United Kingdom.

If you have any questions, email us at support@givewithlegacy.com.

Summary of key points

What do we collect? The information you give us, such as your name, email address, donations, Gift Aid details and Care Page content. We also receive some information from the partners who help us run Legacy, and collect technical information about how you use our services.

Do we collect sensitive information? We do not ask for it. But the causes you support, and anything you write on a Care Page, could reveal things like your health or beliefs.

How do we use it? To run your account, process your donations and Gift Aid through Charities Trust, run Care Pages, keep Legacy safe, improve our services and, where you have agreed or the law allows, send you news and updates.

Who do we share it with? Charities Trust, which receives your donations. The creator of any Care Page you give through, who sees limited details of your gift. The providers who help us run Legacy. Authorities, where the law requires it. We never sell your personal information.

What is public? Care Pages are public. If you give through one, your name only appears if you choose to show it.

How long do we keep it? For as long as you have an account. If you close it, we anonymise your information, but keep the donation and Gift Aid records the law requires for up to seven years.

What are your rights? You can ask to access, correct or delete your information, and object to some uses of it. If you are unhappy, tell us first. You can also complain to the Information Commissioner’s Office.

Table of contents

1. What information do we collect?
2. How do we use your information?
3. What legal bases do we rely on?
4. Share To Care: what is public and who sees what
5. Who do we share your information with?
6. Do we send your information outside the UK?
7. Do we use cookies and similar technologies?
8. How long do we keep your information?
9. How do we keep your information safe?
10. Do we collect information from children?
11. What are your rights?
12. How can you complain?
13. Do we make automated decisions about you?
14. Do we update this policy?
15. How can you contact us?
16. How can you close your account?

1. What information do we collect?

In short: The information you give us, some information from the partners who help us run Legacy, and technical information about how you use our services.

Information you give us

What we collect depends on how you use Legacy:

• Your account. Your name and email address, and your password, which is stored by our sign-in provider, Clerk, and never seen by us. If you sign in with Apple or Google, we receive the name and email address they share with us.
• Your giving. The causes you choose, how much you give and how often, any tip you add, and your receipts and giving history.
• Direct Debit. Stripe collects your bank details when you set up a Direct Debit. We receive your billing address, your sort code and the last four digits of your account number. We use your billing postcode to work out your general area, so that the app can show you causes near you.
• Gift Aid. If you add Gift Aid: your name, home address and postcode, your declaration that you are a UK taxpayer, and whether you have agreed to or cancelled Gift Aid.
• Identity checks. If we need to check a donation, for example because it is large or unusual: information and documents about your identity or where your money came from.
• Charity contact choices. Whether you have asked for the charities you support to be able to contact you, and how.
• Care Pages. If you create a Care Page: your page address, display name, photo, bio and links, the causes you choose and your reasons for each, your theme and display settings, and our review decisions about your page.
• Giving through a Care Page. If you give through a Care Page without signing in: your first name, surname and email address. We also record whether you chose to show your name on the page.
• Waiting lists. If you join a waiting list, such as the one for Share To Care, your email address.
• Support and feedback. What you tell us when you contact us, and any causes you ask us to add or features you vote for.
• Location searches. If you search for causes near you, the postcode you enter.

If you turn on Face ID or fingerprint sign-in, your sign-in details are stored securely on your device and your device checks your face or fingerprint. We never receive your biometric data.

Information from other organisations

• Stripe, our payment provider: whether your payments succeed and, for Direct Debits, the billing address and bank details described above.
• Apple and Google, if you sign in with them: your name and email address. Apple may give us a private relay address instead of your real one.

Information collected automatically

• Device and app information: your device type, operating system and app version, an identifier for your installation of the app, and your push notification token and settings.
• Usage information: the pages and screens you view, what you tap or click, and how long things take to load, so that we can fix errors and improve our services.
• Log and security information: your IP address, browser type, and the date and time of your requests to our servers. We use this to keep our services secure and to prevent fraud and abuse.
• Care Page views: we count how many times each Care Page is viewed each day. These counts do not identify anyone.

Sensitive information

We do not ask for special category information, such as information about your health, religion, ethnicity, sexual orientation or political opinions. But the causes you support, and anything you write on a Care Page, could reveal it, for example if you back a faith-based or health charity. We only use this information to run Legacy, and it is only made public where you choose to publish it, such as on your own Care Page.

2. How do we use your information?

In short: To run Legacy, process your donations and Gift Aid, run Care Pages, keep everyone safe, improve our services and keep in touch.

We use your information to:

• run your account: create it, let you sign in and keep it working;
• process your donations: take payments, pass donations to Charities Trust for the causes you choose, and send you receipts;
• claim Gift Aid: pass your Gift Aid details to Charities Trust so that it can claim Gift Aid from HMRC on your donations;
• pass on your charity contact choices, if you have asked for charities to be able to contact you;
• run Share To Care: review and publish Care Pages, show the supporter names that people choose to show, and give creators their page’s statistics;
• send you service messages, such as receipts, sign-in codes, and updates about your Care Page, for example when it goes live or receives a gift;
• send you push notifications, if you allow them;
• show you causes near you;
• help you when you contact our support team;
• keep Legacy safe: check content, deal with reports, prevent fraud and card testing, and secure our systems;
• check donations: where needed, confirm your identity or where your money came from, to prevent money laundering and comply with sanctions law;
• improve Legacy: understand how our services are used, measure performance and fix errors;
• send you updates you have asked for, such as Share To Care news if you join its waiting list. You can unsubscribe at any time; and
• run our organisation: keep accounts, meet our legal and tax obligations, and deal with complaints and legal claims.

We never sell your personal information, and we do not use it for targeted advertising.

3. What legal bases do we rely on?

In short: UK data protection law requires a lawful basis for each way we use your information. These are the ones we rely on.

• Contract. Where we need your information to provide what you have asked for, such as your account, your donations and Gift Aid, your Care Page, service messages and support.
• Legal obligation. Where the law requires it, such as keeping donation and Gift Aid records for tax purposes, keeping accounts, dealing with illegal content, complying with sanctions and anti-money laundering law, and responding to lawful requests from authorities.
• Legitimate interests. Where we have a good reason that is not outweighed by your rights and interests, such as keeping our services secure, preventing fraud, checking a donor’s identity or where their money came from, checking content, showing creators what their page has raised, understanding how our services are used so that we can improve them, showing you causes near you, and defending legal claims. You can object to these uses.
• Consent. Where we ask for it, such as showing your name on a Care Page, passing your contact details to charities, sending push notifications, and adding you to a waiting list. You can withdraw your consent at any time.
• Vital interests. In rare cases, to protect someone’s life or safety.

Where your Care Page reveals special category information about you, we rely on the fact that you have chosen to make it public.

4. Share To Care: what is public and who sees what

In short: Care Pages are public. Supporters’ names are only shown if they choose. Creators see limited details of the gifts made through their page.

If you create a Care Page

• Once we approve it, your Care Page is public. It shows your display name, photo, bio and links, the causes you have chosen and your reasons for each, and, unless you switch them off, your page’s totals and recent supporters.
• Search engines can list your page, and your name and photo appear in the preview when someone shares a link to it.
• Our team reviews your page before it goes live and whenever you change certain details, and can see your name and email address while doing so.
• When you take your page offline, it stops being public straight away. We keep your draft so that you can publish it again.

If you give through a Care Page

• Your name only appears on the page if you switch on “Show my name”. It then shows as your first name and surname initial, to visitors and to the creator. An automatic filter checks names before they are shown. If it refuses yours, your gift shows as coming from “Someone”.
• The creator can see the amount, cause and time of your gift, whether it is your first gift through their page, and your name if you chose to show it. We also tell them when your gift comes in, including any Gift Aid added to it. They never see your email address, home address or payment details.
• Unless the creator has switched amounts off, your gift may be listed on the page with its amount even if you do not show your name.
• If you give without signing in, we set up a Legacy account with your name and email address so that you can find your donation, receipts and Gift Aid later. You do not have to use it, and you can ask us to close it.
• To remove your name from a Care Page, email support@givewithlegacy.com. The creator can also hide your name.

5. Who do we share your information with?

In short: The charity partner that receives your donations, the providers who help us run Legacy, and others only where the law requires it. We never sell your information.

• Charities Trust (registered charity 327489), which receives our matching payments for the causes you choose and claims Gift Aid. With each donation we send it your email address and the amount for each cause, your charity contact choices and, if you have added Gift Aid, your name and home address. Charities Trust uses this information as a separate controller under its own privacy policy, and shares Gift Aid details with HMRC to make claims. If we check your identity or where your money came from, we may also share the results, and any documents you gave us, with Charities Trust.
• The charities you support, only if you have chosen to let them contact you. Charities Trust passes them your contact details for the ways you picked.
• Creators, as described in section 4.
• Service providers that handle information for us under contracts requiring them to keep it secure and use it only on our instructions:
  • Stripe, which takes card and Direct Debit payments. Stripe also uses some information as a separate controller, for example to prevent fraud, under its own privacy policy.
  • Clerk, for sign-in and account security.
  • Amazon Web Services, which hosts our servers, databases and file storage in London.
  • Cloudflare, which hosts our websites, protects them from attacks, and runs Turnstile, which checks that people giving through Care Pages are not bots.
  • Postmark, which sends our service emails, such as receipts.
  • EmailOctopus, which sends some of our service emails and our waiting list emails.
  • Datadog, which monitors errors and performance in our app and websites.
  • Google Analytics, which gives us statistics about how our marketing website is used.
  • Expo, which delivers push notifications.
  • Slack, which carries alerts to our team, for example when a donation is made, with email addresses partly hidden.
  • Xero, our accounting software, which receives payment amounts and references but no contact details.
• Professional advisers, such as our accountants, auditors and lawyers.
• Authorities, such as HMRC, the police, regulators or courts, where the law requires it, or where it is necessary to prevent fraud or protect people from harm.
• A successor organisation, if we merge, restructure or transfer our services, which must protect your information in the same way.

6. Do we send your information outside the UK?

In short: Our main systems are in the UK, but some of our providers are based abroad. When your information leaves the UK, we make sure it is protected.

Our servers, databases and file storage are hosted by Amazon Web Services in London. Some of our providers are based in the United States, including Stripe, Clerk, Cloudflare, Postmark, Google, Expo and Slack, and Datadog stores our monitoring data in the European Union.

When your information is sent outside the UK, we make sure it is protected. Either the UK government has approved the protection it gets in that country, as it has for the European Union and for US companies certified under the UK Extension to the EU-US Data Privacy Framework, or we use contracts approved for the purpose, such as the UK International Data Transfer Agreement. Contact us if you would like more information.

7. Do we use cookies and similar technologies?

In short: We use a small number of cookies and similar technologies to sign you in, keep checkout working, protect our services and understand how they are used.

• Our website (givewithlegacy.com) uses Google Analytics, which sets cookies (named _ga, and _ga_ followed by an ID) to count visits and show us how people use the site, for example which pages they visit. We also keep a note in your browser’s session storage of how long you have been on the site, so that we can measure engagement. You can opt out of Google Analytics with Google’s opt-out browser add-on or by blocking cookies in your browser.
• Care Pages (care.givewithlegacy.com) do not set cookies of our own. We use Datadog to measure errors and performance on them without cookies. When you give, your browser keeps the details you enter in session storage until your payment is complete, Cloudflare Turnstile checks that you are not a bot, and Clerk, our sign-in provider, sets cookies to sign you in or verify your email address. Stripe’s payment page is run by Stripe under its own policies.
• The creator studio (my.givewithlegacy.com) uses Clerk’s cookies to keep you signed in, and a Datadog cookie (_dd_s) that links the pages you view in one visit when we measure errors and performance.
• The Legacy app uses Datadog to record how the app is used, along with errors and crashes. News videos in the app use YouTube’s player, which may set cookies or collect information about your device under Google’s privacy policy.

Most browsers let you block or delete cookies. If you block the cookies our sign-in provider uses, you will not be able to sign in.

8. How long do we keep your information?

In short: For as long as we need it for the reasons in this policy. Donation and Gift Aid records are kept for up to seven years, because the law requires it.

• Your account: while it is open. When you ask us to close it, we anonymise your personal information within one month, apart from the records below.
• Donation, Gift Aid and payment records: for six years after the end of the financial year in which you gave, so up to seven years, because tax, Gift Aid and accounting rules require it. After that, we anonymise them.
• Identity checks: for as long as we keep the donation records they relate to.
• Care Pages: while your page exists. If you ask us to remove it, we take it down and anonymise it within one month. Records of gifts made through it are kept as above.
• Supporter names on Care Pages: while the page exists, unless you ask us to remove yours.
• Waiting lists: until you unsubscribe or the waiting list closes.
• Support conversations: for as long as we need them to help you and to keep a record of what we agreed.
• Logs and monitoring data: for two months, after which they are deleted automatically.
• Backups: our database backups are deleted after seven days.

9. How do we keep your information safe?

In short: We use technical and organisational measures to protect your information.

Our database is encrypted when stored, your information is encrypted in transit, and access to personal information is limited to the people and providers who need it. Card and bank details are handled by Stripe, which meets the payment industry’s security standard (PCI DSS).

No system is completely secure, so we cannot guarantee that your information will never be accessed without permission. If something goes wrong, we will act quickly and, where the law requires it, tell you and the Information Commissioner’s Office.

10. Do we collect information from children?

In short: Legacy is for people aged 18 and over.

You must be 18 or over to use Legacy or create a Care Page. We do not knowingly collect information from anyone under 18. If we learn that we have, we will close the account and anonymise the information, apart from any donation records the law requires us to keep. If you think we hold information about someone under 18, email support@givewithlegacy.com.

11. What are your rights?

In short: You have rights over your personal information, including to access, correct and delete it.

Under UK data protection law, you have the right to:

• access the personal information we hold about you, and get a copy of it;
• correct information that is wrong or incomplete;
• erase your information, for example where we no longer need it or you have withdrawn your consent. Because Legacy handles donations, we do this by closing your account and anonymising your information, keeping only the records the law requires;
• restrict how we use it, for example while we check that it is accurate;
• object to how we use it where we rely on legitimate interests, and to direct marketing at any time;
• move information you have given us to another organisation;
• withdraw your consent at any time, where we rely on it. This does not affect anything we did before you withdrew it; and
• ask a person to review a decision made about you by automated means (see section 13).

Some of these rights have limits. For example, we cannot erase donation and Gift Aid records that the law requires us to keep.

To use any of these rights, email support@givewithlegacy.com. We may ask you to confirm your identity. We will respond within one month, or tell you within that time if we need longer because your request is complex. There is normally no fee.

You can also change some choices yourself: your Gift Aid declaration and charity contact choices in the app’s settings, push notifications in your device settings, and emails using the unsubscribe link in any news or update we send.

12. How can you complain?

In short: Tell us first. If you are still unhappy, you can complain to the Information Commissioner’s Office.

If you are unhappy with how we have used your personal information, email support@givewithlegacy.com with “Data complaint” in the subject line. We will acknowledge your complaint within 30 days, look into it, and tell you what we found and what we are doing about it.

If you are not satisfied with our response, you can complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator, at ico.org.uk or on 0303 123 1113.

13. Do we make automated decisions about you?

In short: No decision with legal or similarly significant effects is made about you by automated means alone.

Some checks are automatic. Stripe screens payments for fraud and may decline one, Cloudflare Turnstile checks that visitors are not bots, our systems limit how many donations can be made in a short time, and our filter decides whether a supporter’s name can be shown on a Care Page. If you think an automatic check got it wrong, contact us and a person will look at it.

14. Do we update this policy?

In short: Yes. We will tell you about important changes.

We update this policy when our services or the law change. The “Last updated” date at the top shows when it last changed. If we make an important change, we will tell you by email or in the app before it takes effect.

15. How can you contact us?

Email us at support@givewithlegacy.com or write to us at:

Stewards Of Tomorrow Ltd
C/O West & Berry Limited
Nile House
Nile Street
Brighton
BN1 1HW
United Kingdom

16. How can you close your account?

To ask us to close your account and anonymise your personal information, use our delete account form or email support@givewithlegacy.com. We will process your request within one month and email you when it is done.

Because Legacy is a giving platform, we cannot delete your records outright. We keep a limited record of any donations you have made, including Gift Aid declarations, amounts, dates and the charities you gave to, for up to seven years because the law requires it.