This policy was last updated on 24th March 2021

Thank you for choosing to be part of our community at Makor Hayim (including Shir Hayim,“we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our privacy notice, or our practices with regards to your personal information, please contact us at DPO@makorhayim.org.

When you visit our websites (www.makorhayim.org, makorhayim.co.uk, shirhayim.org) and related mobile applications, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Sites or Apps and our services.

This privacy notice applies to all information collected through our websites (makorhayim.org, makorhayim.co.uk, shirhayim.org), any mobile application, (“Apps”), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the “Services”).

Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. INTERNET AND CCTV 

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. WHAT ARE YOUR PRIVACY RIGHTS?

7. DATA BREACH

8. CALIFORNIA RESIDENTS SPECIFIC PRIVACY RIGHTS

9. UPDATES TO THIS NOTICE

10. REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU 

11. CONTACT US ABOUT THIS NOTICE

12. REFORM JUDAISM PRIVACY AND INFORMATION SHARING POLICY

1. WHAT INFORMATION DO WE COLLECT?

The legal basis for processing your personal data is that we have a legitimate interest in doing so.   The legitimate interest being pursued is that as a Synagogue and community organisation we need to hold a certain amount of personal data relating to our members, whom we refer to as Builders, so that we can communicate with them and manage their membership, together with limited information on guests and visitors.  

In using and attending our events or services you consent to the collection and use of your Personal Data as set out in this privacy notice.  

We collect personal information about you directly from you and your family that you provide to us such as name, address, contact information, passwords and security data, and payment information. This is primarily done through application forms (for example membership application forms, event booking forms and education booking forms) and emails. Where you have family under the age of 21, we will therefore collect information that you provide to us on the minors in your family.

We collect personal information when participating in activities or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. 

On occasion, we may add information about you when received from another visitor/member of the Synagogue, a family member, or a third party where it is relevant and we have confidence it is accurate.   This typically happens when someone else is registering another guest for an event, or using a third-party website and you have given your consent to them.  We may combine information that we already have about you with information available publicly from external sources in order to gain a better understanding of you.  This may include social media sites.

If you provide information for another person, you need to first ensure they agree for you to do so and be clear about what information you will provide.  You must inform them of where they can find our privacy notice.  

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A full list of data we may hold about you can be found in our Personal Data Audit document, which can be provided upon request.  A top-level overview of the data we may hold for each person includes; 

1. Personal information including name, gender, contact details, date of birth, family members, next of kin details, employment details, education details, car registration details, events attended, DBS information 
2. Medical information including allergies, medication details, medical history, learning difficulties
3. Religious information including Hebrew name, yahrzeit dates, Bar Mitzvah details, marriage details, conversion details, family member details
4. Membership details including date of joining, rate of membership, burial scheme information
5. Financial information including bank details, all monies paid/donated, direct debit mandates, gift aid declarations, legacy commitments
6. Visitor security form information including current and previous home addresses, ID documents (deleted after verification), job information
7. Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information collected through our Apps

We may collect information regarding you when you use our apps.

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2. HOW DO WE USE YOUR INFORMATION?

We use the information to provide you with information about products and services in keeping with our operation as a Synagogue and Jewish community.  This includes: 

1. Information regarding our religious services 
2. Information regarding upcoming events, both run by us and by third parties that we deem may be of interest 
3. To provide you with religious information in line with our Vision, Values and Inclusion Statement, a copy of which is found here: 
4. To ask you to take part in community activities, for example helping to prepare Kiddush, security rotas, mitzvot. 
5. To meet pastoral and welfare needs
6. For membership fees, donations, fundraising purposes and/or to collect Gift Aid
7. For general promotional and marketing materials and activities 
8. For market research purposes and to monitor and improve our service to you 
9. To provide services and opportunities fitting for a Synagogue 
10. As otherwise permitted or required by any applicable law or regulation 

We may contact you be email, letter, via social media, phone, text message or WhatsApp.

If there are any changes to your Personal Data, or if you become aware that we have inaccurate Personal Data relating to you, please contact us immediately.  We cannot be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you have provided us.  

We may occasionally use profiling techniques in order to target our communications effectively – e.g. To advertise information to someone of a particular age group, or within a certain location, or to assess the level of donation you may be able to give. 

A limited number of members of Makor Hayim, who have responsibility for an event or activity, may have access to your data and may contact you.  They will only use your data for the limited purpose of their volunteering role.

In order to help us communicate with you and to store data cost-effectively we use various third party solutions, including Gmail and Google Workspace (as our primary database), Xero (accounting software).  As such, your information may be transferred and stored in countries outside the European Economic Area (EEA), including some that may not have the same level of protection of Personal Data as are enjoyed within the EEA.  

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3.WILL YOUR INFORMATION BE SHARED WITH ANYONE?

Makor Hayim is a member of Reform Judaism and we share information with Reform Judaism about our members on an anonymised basis and, where you have given your consent in a membership application form, limited personal information about you and your family. Further information about Reform Judaism’s policy on information sharing is provided below.

Makor Hayim is also a member of the Joint Jewish Burial Scheme (JJBS) and as a member, you are automatically enrolled in that Scheme, unless you have made arrangements under another burial scheme, or you live abroad. We provide limited personal information about you and your family to JJBS. If you terminate your membership of Makor Hayim and join another Synagogue, we will provide limited personal information about you and your family to that Synagogue upon its request, solely in connection with your continuing membership of JJBS.  JJBS’ privacy policy is here. 

Other than Reform Judaism and JJBS, as detailed above, we will never give, sell, share or trade your information to a third party unless we have your explicit consent to do so or are required to do so by a court of competent jurisdiction or an official regulator or if they are authorised to act on our behalf.

4. INTERNET AND CCTV 

No data transmission over the internet is 100% secure.  As a result, whilst we try to protect your personal information, we cannot guarantee the security of any information you transmit to us.  

1. Our website may uses cookies (small software programmes that sit on your browser to improve the speed with which information can appear on your screen).  This may provide us with information as to how users use our online services.  If you do not wish to receive cookies, you may be able to block them on your browser.  
2. When you receive newsletters and emails from us, such newsletters and emails may contain technologies to track, for market research purposes, whether you opened those newsletters and emails and whether you accessed internet links contained within those emails.  
3. Our website may include links to other sites, not owned or managed by us.  We cannot be held responsible for the privacy of information collected by these websites.  
4. We do not place personal data on our website or materials other than names of members.  
5. We have a photography policy and may upload photographs of our events and members to our website and social media profiles in with your prior written consent.  
6. We do not accept responsibility for the protection of any data publicly included on our website and on social media sites. 
7. Makor Hayim may hold services in buildings which have a CCTV system which records activity on the grounds and in the building.  The purpose of the CCTV will be for security and to help with accidents and crime prevention.  The CCTV may be primarily accessed by Community Security Trust (CST) and the security, house, management and reception teams of the building to aid their ability to carry out their daily tasks. The Police, CST and other security organisations may access these CCTV archives.  

5. HOW LONG DO WE KEEP YOUR INFORMATION?

The length of time which we will hold on to your data will be in line with our policies set out in our Personal Data Audit document, which can be provided upon request.  We typically hold most information (but not all) indefinitely, unless requested otherwise. This includes information of over members over 21 years old that do not join the Synagogue on reaching the age of 21, unless requested otherwise.  This is so as we can continue to offer you services that may be of interest to you and so we can help you in the future if you choose to re-join, or request a specific part of information from us. 

6. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

7. DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Makor Hayim believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Makor Hayim becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Makor Hayim will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

8. CALIFORNIA RESIDENTS SPECIFIC PRIVACY RIGHTS

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services or Apps, you have the right to request removal of unwanted data that you publicly post on the Services or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

9. UPDATES TO THIS NOTICE

We will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

10. REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form as below. We will respond to your request within 30 days.

11. CONTACT US ABOUT THIS NOTICE

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) Martin Dives by email at DPO@makorhayim.org, or by post to:

Makor Hayim

56 Milverton Road

London

NW6 7AP

United Kingdom

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk