1. This privacy policy applies only to the actions of Vhani
Foundationand Users with respect to this Website. It does
not extend to any websites that can be accessed from this
Website including, but not limited to, any links we may
provide to social media websites.
2. For purposes of the applicable Data Protection Laws,
Vhani Foundation is the “data controller”. This means that
Vhani Foundation determines the purposes for which, and
the manner in which, your Data is processed.

We may collect the following Data, which includes personal
Data, from you:
1. name;
2. contact Information such as email addresses and
telephone numbers;
3. financial information such as credit / debit card numbers;
3.1 IP address (automatically collected);
3.2 web browser type and version (automatically collected);
3.3. Operating system (automatically collected);
 a list of URLs starting with a referring site, your activity on
this Website, and the site you exit to (automatically
collected);
 Channel consent, means to contact, Tax Payer status;
 In each case, in accordance with this privacy policy.

Vhani Foundation will collect your Data in a number of ways, for
example:
 when you contact us through the Website, by telephone,
post, e-mail or through any other means;
 when you register with us and set up an account to
receive our products/services;
 when you enter a competition or promotion through a
social media channel;
 when you make payments to us, through this Website or
otherwise;
 when you elect to receive marketing communications from
us;

In each case, in accordance with this privacy policy.

To the extent that you access the Website, we will collect your
Data automatically, for example:
 We automatically collect some information about your visit
to the Website. This information helps us to make
improvements to Website content and navigation, and
includes your IP address, the date, times and frequency
with which you access the Website and the way you use
and interact with its content.

Any or all of the above Data may be required by us from time to
time in order to provide you with the best possible service and

experience when using our Website. Specifically, Data may be
used by us for the following reasons:
 internal record keeping;
 improvement of our products / services;
 transmission by email of marketing materials that may be
of interest to you;

 We may use your Data for the above purposes if we deem
it necessary to do so for our legitimate interests. If you are
not satisfied with this, you have the right to object in
certain circumstances (see the section headed “Your
rights” below);
 For the delivery of direct marketing to you via e-mail, we’ll
need your consent, whether via an opt-in or soft-opt-in:
8.1 Soft opt-in consent is a specific type of consent which
applies when you have previously engaged with us (for
example, you contact us to ask us for more details about a
particular product/service, and we are marketing similar
products/services). Under “soft opt-in” consent, we will take
your consent as given unless you opt-out;
8.2 for other types of e-marketing, we are required to obtain
your explicit consent; that is, you need to take positive and
affirmative action when consenting by, for example, checking a
tick box that we’ll provide;
 if you are not satisfied about our approach to marketing,
you have the right to withdraw consent at any time. To find
out how to withdraw your consent, see the section headed
“Your rights” below.
 When you register with us and set up an account to
receive our services, the legal basis for this processing is
the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract.

8.3 Who we share Data with?

8.3.1 We may share your Data with the following groups of
people for the following reasons:
8.3.2 Our employees, agents and/or professional advisors – to
obtain requirements and professional advice from the advisors;
8.3.3 Third party service providers who provide services to us
which require the processing of personal data – system
development like database management the system developer
have access to the database;
8.3.4 Third party payment providers who process payments
made over the Website – PayPal / is a secure gateway that
handles all the information at its end we don’t keep any
payment related data;

In each case, in accordance with this privacy policy.

We will use technical and organisational measures to
safeguard your Data, for example:
 Access to your account is controlled by a password and a
user name that is unique to you.
 We store your Data on secure servers.
 Payment details are encrypted using SSL technology
(typically you will see a lock icon or green address bar (or
both) in your browser when we use this technology.
 Technical and organisational measures include measures
to deal with any suspected data breach. If you suspect
any misuse or loss or unauthorised access to your Data,
please let us know immediately by contacting us via this e-
mail address: info@vhanifoundation.org
 If you want detailed information from Get Safe Online on
how to protect your information and your computers and

devices against fraud, identity theft, viruses and many
other online problems, please visit
www.getsafeonline.org Get Safe Online is supported by
HM Government and leading businesses.

 Unless a longer retention period is required or permitted
by law, we will only hold your Data on our systems for the
period necessary to fulfil the purposes outlined in this
privacy policy or until you request that the Data be
deleted.
 Even if we delete your Data, it may persist on backup or
archival media for legal, tax or regulatory purposes.

You have the following rights in relation to your Data:
11.1 Right to access – the right to request (i) copies of the
information we hold about you at any time, or (ii) that
we modify, update or delete such information. If we
provide you with access to the information, we hold
about you, we will not charge you for this, unless your
request is “manifestly unfounded or excessive.” Where
we are legally permitted to do so, we may refuse your
request. If we refuse your request, we will tell you the
reasons why.
 Right to correct – the right to have your Data rectified if it
is inaccurate or incomplete.
 Right to erase – the right to request that we delete or
remove your Data from our systems.
 Right to restrict our use of your Data – the right to “block”
us from using your Data or limit the way in which we can
use it.
 Right to data portability – the right to request that we
move, copy or transfer your Data.

 Right to object – the right to object to our use of your Data
including where we use it for our legitimate interests.
 To make enquiries, exercise any of your rights set out
above, or withdraw your consent to the processing of your
Data (where consent is our legal basis for processing your
Data), please contact us via this e-mail address:
info@vhanifoundation.org
 If you are not satisfied with the way a complaint you make
in relation to your Data is handled by us, you may be able
to refer your complaint to the relevant data protection
authority. For the UK, this is the Information
Commissioner’s Office (ICO). The ICO’s contact details
can be found on their website at https://ico.org.uk
 It is important that the Data we hold about you is accurate
and current. Please keep us informed if your Data
changes during the period for which we hold it.

 Data which we collect from you may be stored and
processed in and transferred to countries outside of the
European Economic Area (EEA). For example, this could
occur if our servers are located in a country outside the
EEA or one of our service providers is situated in a
country outside the EEA. We also share information with
our group companies, some of which are located outside
the EEA.
 We will only transfer Data outside the EEA where it is
compliant with data protection legislation and the means
of transfer provides adequate safeguards in relation to
your data, eg by way of data transfer agreement,
incorporating the current standard contractual clauses
adopted by the European Commission, or by signing up to
the EU-US Privacy Shield Framework, in the event that

the organisation in receipt of the Data is based in the
United States of America.
 To ensure that your Data receives an adequate level of
protection, we have put in place appropriate safeguards
and procedures with the third parties we share your Data
with. This ensures your Data is treated by those third
parties in a way that is consistent with the Data Protection
Laws.

This Website may, from time to time, provide links to other
websites. We have no control over such websites and are not
responsible for the content of these websites. This privacy
policy does not extend to your use of such websites. You are
advised to read the privacy policy or statement of other
websites prior to using them.

12.1 Changes of business ownership and control

 Vhani Foundation 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 Vhani Foundation.
Data provided by Users will, where it is relevant to any
part of our business so 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 the Data for the purposes for which it was originally
supplied to us.
 We may also disclose Data to a prospective purchaser of
our business or any part of it.
 In the above instances, we will take steps with the aim of
ensuring your privacy is protected.

12.2 General

 You may not transfer any of your rights under this privacy
policy to any other person. We may transfer our rights

under this privacy policy where we reasonably believe
your rights will not be affected.
 If any court or competent authority finds that any provision
of this privacy policy (or part of any provision) is invalid,
illegal or unenforceable, that provision or part-provision
will, to the extent required, be deemed to be deleted, and
the validity and enforceability of the other provisions of this
privacy policy will not be affected.
 Unless otherwise agreed, no delay, act or omission by a
party in exercising any right or remedy will be deemed a
waiver of that, or any other, right or remedy.
 This Agreement will be governed by and interpreted
according to the law of England and Wales. All disputes
arising under the Agreement will be subject to the
exclusive jurisdiction of the English and Welsh courts.

12.3 Changes to this privacy policy

Vhani Foundation reserves the right to change this privacy
policy as we may deem necessary from time to time or as may
be required by law. Any changes will be immediately posted on
the Website and you are deemed to have accepted the terms of
the privacy policy on your first use of the Website following the
alterations. You may contact Vhani Foundation by email at
info@vhanifoundation.org

12.4 Policy on Political Activities & Terrorism

Vhani Foundation is a community interest company (CIC), non-
profit voluntary Charitable Organization and NGO operates in
London borough of districts the United Kingdom (UK) and, as
such, it is prohibited by its corporate character to participate in
any type of political activities or in any non-charitable functions
which may conflict with its obligation under the Charity
Commission’s directions and under the Terrorism Act 2001.

These prohibitions apply equally to all persons who work for
and or represent Vhani Foundation in any capacity.
 In addition, Vhani Foundation volunteers should not
(unless authorised in writing) render an opinion or make a
statement to the media or in any social gathering, unless
he/she prefaces that such statements or opinions are
solely his/hers and they do not reflect the opinions or
position of Vhani Foundation.

12.5 Confidentiality

 The Volunteer shall not make use of, divulge or
communicate to any person any trade secrets or other
confidential information of or relating to Vhani Foundation,
or that of other persons or bodies with whom Vhani
Foundation’s has dealings of any sort, which the
‘Volunteer’ may have received or obtained, or has
otherwise been acquired by them in confidence, whilst
engaging for Vhani Foundation.

 All material, whether held on paper, electronically or
magnetically which was made or acquired by the
‘Volunteer’ during the course of engagement, belongs to
Vhani Foundation.

 As a volunteer of Vhani Foundation, I will not engage
myself in any actions or activities which may be
detrimental to the organisation’s continued good standing
within the legal/social community at large.
 I agree to refrain from any and all activities which may
conflict with Vhani Foundation obligations, purpose and

goals. Furthermore, I agree in the event that I may be
called upon to render an opinion or make statements to
the media or in any social gathering, to preface that such
statements or opinions are solely mine and that they do
not reflect the opinions or position of Vhani Foundation
 I irrevocably covenant, promise and agree to indemnify
Vhani Foundation and hold it harmless from and against
any and all losses, claims, expenses, demands, damages,
or liabilities, of whatever kind or nature which Vhani
Foundation may sustain or to which it may become
subject arising out of or relating in any way to my
participation in any activities in conflict with Vhani
Foundation’s obligation under Part II of the Terrorism Act
of 19 February 2006, including in defending against or
enforcing any such losses, claims, expenses, suits,
damages, or liabilities.
 This document is executed by me knowingly, intelligently
and voluntary.