PRIVACY POLICY

www.tonibobandlou.com Privacy Policy

Type of website: Community Interest Company

Effective date: 15th day of July, 2024

www.tonibobandlou.com (the "Site") is owned and operated by TONIBOBANDLOU C.I.C..

TONIBOBANDLOU C.I.C. is the data controller and can be contacted at:

info@tonibobandlou.com

Purpose

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of

the following:

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected;

4. The rights of Site users; and

5. The Site's cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.


GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.


We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.


Consent

By using our Site users agree that they consent to:


  1. The conditions set out in this Privacy Policy.


When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.


You can withdraw your consent by: contacting us at info@tonibobandlou.com and asking us to withdraw consent.


Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal basis to collect and process the personal data of users in the EU:


1. Users have provided their consent to the processing of their data for one or more specific purposes.


Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.


Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:


  1. First and last name; and


2. Email address.


This data may be collected using the following methods:


  1. By completing a form on our website.


How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect when the user performs certain functions may be used for the following purposes:


1. For communication and get in contact with the person who has completed the form..


Who We Share Personal Data With

Employees

We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.


Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:


1. If the law requires it;


2. If it is required for any legal proceeding;


3. To prove or protect our legal rights; and


4. To buyers or potential buyers of this company in the event that we seek to sell the company.


If you follow hyperlinks from our Site to another Site, please note that we are not

responsible for and have no control over their privacy policies and practices.


How Long We Store Personal Data

User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.


How We Protect Your Personal Data

In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee's termination.


While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.


Your Rights as a User

Under the GDPR, you have the following rights:


1. Right to be informed;


2. Right of access;


3. Right to rectification;


4. Right to erasure;


5. Right to restrict processing;


6. Right to data portability; and


7. Right to object.


Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.


How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact: 

info@bookofboobs.org


Cookie Policy

A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.


We use the following types of cookies on our Site:


1. Functional cookies

Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;


2. Analytical cookies

Analytical cookies allow us to improve the design and functionality of our Site by

collecting data on how you access our Site, for example data on the content you

access, how long you stay on our Site, etc; and


3. Targeting cookies

Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalise the information you see on our Site for you.


Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.


Complaints

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner's Office in the UK, Data Protection Commission in Ireland.


Contact Information

If you have any questions, concerns or complaints, you can contact info@bookofboobs.org


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TERMS & CONDITIONS


These terms and conditions (the "Terms and Conditions") govern the use of www.tonibobandlou.com (the "Site"). This Site is owned and operated by TONIBOBANDLOU C.I.C. This Site is a Community Interest Company.


By using this Site, you indicate that you have read and understand these Terms and Conditions and agree to abide by them at all times.


Intellectual Property

All content published and made available on our Site is the property of TONIBOBANDLOU C.I.C and the Site's creators. This includes, but is not limited to images, text, logos, documents, downloadable files and anything that contributes to the composition of our Site.


Limitation of Liability

TONIBOBANDLOU C.I.C and our directors, officers, agents, employees, subsidiaries, and affiliates will not be liable for any actions, claims, losses, damages, liabilities and expenses

including legal fees from your use of the Site.


Indemnity

Except where prohibited by law, by using this Site you indemnify and hold harmless TONIBOBANDLOU C.I.C and our directors, officers, agents, employees, subsidiaries, and

affiliates from any actions, claims, losses, damages, liabilities and expenses including legal fees arising out of your use of our Site or your violation of these Terms and Conditions.


Applicable Law

These Terms and Conditions are governed by the laws of the Country of England.


Severability

If at any time any of the provisions set forth in these Terms and Conditions are found to be inconsistent or invalid under applicable laws, those provisions will be deemed void and will be removed from these Terms and Conditions. All other provisions will not be affected by the removal and the rest of these Terms and Conditions will still be considered valid.


Changes

These Terms and Conditions may be amended from time to time in order to maintain compliance with the law and to reflect any changes to the way we operate our Site and the way we expect users to behave on our Site. We will notify users by email of changes to these Terms and Conditions or

post a notice on our Site.


Contact Details

Please contact us if you have any questions or concerns. Our contact details are as follows:

______________________________________

info@tonibobandlou.com

______________________________________

You can also contact us through the feedback form available on our Site.

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TONIBOBANDLOU CIC Ethical Fundraising Policy


This policy sets out how we manage the ethical issues and social responsibility within fundraising.  

Specifically, we aim at all times to be open, honest, fair and to operate in a legal way that meets not only the law, but also fundraising regulation and best practice, including the UK Fundraising Regulator’s Code of Fundraising Practice.

Everyone who is involved in fundraising has a responsibility to be aware of and comply with the ethical issues and procedures in this policy. 


People And Organisations


Approach

We will always be honest about what we can achieve when asking for funds, submit realistic budgets, use the funds for the purpose intended and ensure that we provide any reports required, on time. 

We will ensure that everyone in the organisation is aware of and consistently complies with the regulatory guidance on fundraising behaviours and respond promptly and effectively to any fundraising complaints

We comply with all relevant UK laws and regulatory guidelines, including those issued by HMRC and the Fundraising Regulator.

Supporters

Supporters have a right to expect us to be open and to provide clear, truthful information on our work, including reporting on how we intend to and do spend the funding we are given and managing donors' information responsibly.

We will respect the privacy and contact preferences of our donors. We will respond promptly to requests to cease contacts or complaints and act to address their causes.

Beneficiaries

How we represent our beneficiaries, in our communications, is always respectful of them and portrays them in the way they would wish to be seen. We will only use personal information that they have given consent for and for the purposes they have agreed and will not disclose anything that might put them at risk, particularly children and vulnerable people.

Donors

We will ensure that there is not:

  • Unreasonable intrusion on privacy.
  • Unreasonably persistent fundraising.
  • Undue pressure to donate.

And we will not accept a donation that is not in the company’s best interests.

Vulnerable Individuals

In communicating we will be mindful of indicators that may suggest an individual may be vulnerable, using REAL

  • Retain - and repeat the information you give him/her? 
  • Do you have to repeat what you have said over and over again? 

  • Explain I- able to properly explain or communicate the decision they have made? 
  • Are they joining in the discussion or just agreeing with what you are saying? 
  • Are they asking questions that aren’t related to what you are saying? 
  • Able - to understand what they are being told? 
  • Listen – able to listen, follow and understand the discussion taking place, or are they just repeating what you say?

If an individual shows signs of possible vulnerability, we will:

  • Consider communication preferences.
  • Not make assumptions about him/her.
  • Ask him/her what they need and how you can help them better.
  • Empathise and sympathise with him/her.
  • Try asking questions in a different way.
  • Summarise anything that has been decided or agreed in plain English.

We:

  • Will not place any undue pressure on individuals to donate.  
  • Do not either solicit nor accept donations from anyone whom we know or think may not be competent to make their own decisions.  
  • Are sensitive to any particular need that a donor may have. 

Commercial Partners

We will not partner with any organisation that produces goods/services or acts in a way that is contrary to our purposes or values.

We will ensure that any commercial agreement represents a fair deal for the company and.

  • Clearly establishes what we expect to gain from it, prior to entering into an agreement.
  • Set up appropriate systems to monitor and review the partnership. 
  • Take appropriate steps to identify and manage any risks.
  • Ensure from the outset that the expectations of both the company and the partner have been agreed and.
  • Can be managed effectively and appropriately. 

We will disclose any commercial partnerships in our Annual Report. 

Statutory Authorities

We will also be mindful of RR7 - Independence of Charities from the State. In particular, we will ensure that we remain independent and that any funding provided does not discharge the statutory duties of the State. 


Systems And Procedures


Donations

We accept donations on a good faith basis. That is there is a presumption that a donation is acceptable, unless there is evidence to the contrary.  

In deciding to accept, or reject, a donation we balance the impact on our beneficiaries of not accepting the funding, against the impact on our organisation of accepting a donation that should not have been. That may include risks such as harm to our beneficiaries’ interests, reputational damage, loss of public trust and the risk of breaking the law.

We will take reasonable and appropriate steps to know who the organisation's donors are and will not accept a donation where the risk to the organisation is assessed to be greater than the benefit of having the funds donated. There can be no absolute guide to what may be suspicious, but indicators are where significant sums are being donated, particularly if this is unusual, in cash or from overseas. Any prospective donor who wishes cash to be forwarded in advance or for the organisation to pay some of the donation to a third party will always be considered highly suspicious. 


If supporters wish their donation(s) to be used in a specific way, or for a specific purpose, they may make a restricted donation by providing written instructions with their donation. We will always respect this.


Refusals

We abide by the law which requires us, in deciding whether to accept or refuse a donation, to consider which action is in the company's best overall interest.  

We will not accept a donation where there are reasonable grounds to believe:

  • The donation may be an attempted scam, or to launder money or evade tax, or is in some other way illegal.
  • There may be private benefit linked to the donation, such as an obligation to purchase goods or services form a specified company.
  • Conditions attached to the donation are so inflexible that they undermine our independence or are so onerous as to compromise our effectiveness.
  • The cost of accepting the donation would exceed its value.  


Due Diligence

We will undertake reasonable and proportionate due diligence of donors, to ensure they don't hold views or are involved in activities that might be incompatible with our role and damage our reputation. In terms of donations, we will ensure that any gift is safe to accept and, doing so, would be in the best interests of your company. We will also consider issues, such suspicious donations, or managing large anonymous gifts, or those from vulnerable individuals.  

Imagery

If we use AI generated, stock or digitally enhanced imagery, particularly where the subject may be emotive or challenging, we will ensure that the way in which we do so is not reasonably likely to mislead and, potentially, influence people. For example, we may make our policy on its use publicly available and use watermarks, alt text and/or footnotes and/or explain this in content text.  We may not do so where its context and/or content is unlikely to mislead or influence. For example, an image of intergalactic war or use of a stock image on a post about opening hours.  

We recognise that AI deep fakes can be difficult to identify but those using our social media will be made aware of the risk. We will not like, share or support in the comments any imagery or content that we reasonably suspect to be fake.  

Bullying And Abuse

The directors of the company have zero tolerance for abuse, including discrimination, bullying and sexual harassment, not only for fundraising staff and volunteers, but for anyone who is involved with our company. We will maintain a culture of respect and equality, will ensure that there are processes to raise concerns that everyone is aware of and is confident to use and we will deal with any allegations of abuse promptly, sensitively and in accordance with employment and any other laws.

Version Control - Approval and Review

Version 1, approved by Board, May 2025


Donor Privacy Policy


Introduction

TONIBOBANDLOU Community Interest Company (CIC) is committed to protecting the privacy of our donors and maintaining the confidentiality of their personal information. This policy outlines how we collect, use, and safeguard donor data.

Data Collection and Consent

  1. Collection of Information:
  • We collect donor information through various channels, including online forms, events, and direct communication.
  • Types of data collected may include names, contact details, donation history, and preferences.
  1. Consent:
  • Donors provide explicit consent for data collection and use.
  • We clearly communicate the purpose of data collection and seek informed consent.

Data Storage and Security

  1. Secure Storage:
  • Donor data is stored securely using encrypted systems.
  • Access to sensitive information is restricted to authorized personnel.
  1. Data Accuracy:
  • We maintain accurate donor records and regularly update information.
  • Donors can request corrections or updates to their data.
  1. Data Retention:
  • We retain donor data only as long as necessary for our legitimate purposes.
  • Data related to financial transactions is retained for legal and accounting requirements.

Use of Donor Information

  1. Purpose:
  • Donor data is used for communication, acknowledgment, and relationship-building.
  • We may send newsletters, event invitations, and updates related to our mission.
  1. Third Parties:
  • We do not sell or share donor information with third parties for commercial purposes.
  • Trusted service providers (e.g., payment processors) may access data solely for operational purposes.

Transparency and Accountability

  1. Transparency:
  • We inform donors about our privacy practices through our website and communication materials.
  • Donors can request details about their data usage.
  1. Accountability:
  • Our board and staff are responsible for compliance with this policy.
  • We conduct periodic reviews to assess our privacy practices.

Contact Information

For any questions or concerns related to donor privacy, please contact our Data Protection Officer at info@tonibobandlou.com

Medical Disclaimer


All content and media on the TONIBOBANDLOU CIC website is created and published for informational purposes only. It is not intended to be a substitute for professional medical advice and should not be relied on as health or personal advice. TONIBOBANDLOU CIC makes no representation and assumes no responsibility for the accuracy of information contained on or available through this website, and such information is subject to change without notice.

Always seek the guidance of your GP or other qualified health professionals with any questions you may have regarding your health or a medical condition. And never disregard the advice of a medical professional, or delay in seeking it because of something you have read on this website. If you choose to rely on any information provided by TONIBOBANDLOU CIC, you do so solely at your own risk.

External links to other websites or educational material that are not explicitly created by TONIBOBANDLOU CIC are followed at your own risk. Under no circumstances is TONIBOBANDLOU CIC responsible for the claims of third party websites or providers.