The Lullaby Trust (formerly The Foundation for the Study of Infant Deaths) (“we”/ “us” / “our”) is committed to safeguarding your privacy. This is the privacy policy of The Lullaby Trust (the “Policy”). If you feel that The Lullaby Trust is not abiding by this Policy, you should immediately contact the Chief Executive at The Lullaby Trust by email at office@lullabytrust.org.uk and we will try to resolve your concerns.

This Policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998, the data controller is The Lullaby Trust of 11 Belgrave Road London SW1V 1RB.

1. Collection of information

We may collect and process data about you from information that you provide in the following ways:

  • Information that you provide by filling in forms on our site lullabytrust.org.uk (the “Website”). This includes information provided at the time of registering to use the Website or any part thereof, subscribing to our service, posting material or requesting further services;
  • We may also ask you for information when you report a problem with the Website;
  • Information that you provide when placing an order with us by telephone. This includes your name, address and payment details;
  • If you contact us in writing or by telephone, we may keep a record of that correspondence; and
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.We may automatically collect the following information with regard to each of your visits to the Website:
  • Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, operating system and platform,  browser type and version; and
  • Details of your visits to the Website, including but not limited to, the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
  • On the Website we use cookies and other data on your device to distinguish you from other users of the Website. For more information, please see our Cookie Policy at section [6] below.

2. Use of information

We may use information held about you in the following ways:

  • To ensure that content from the Website is presented in the most effective manner for you and for your computer;
  • To administer the Website and for internal operations, including system administration, troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • As part of our efforts to keep the Website safe and secure;
  • To provide you with information that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
  • To allow you to participate in interactive features of our service, when you choose to do so; and
  • To notify you about changes to our service.
    We use IP addresses to analyse trends, administer the Website, track users’ movement and gather broad demographic information for aggregate use.

3. Disclosure of information

We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

  • We may disclose your personal data to third parties in connection with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of The Lullaby Trust, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • When you are using our secure online donation / shopping pages you are going through to a partner company and the information you give to such partner company, such as your credit card number and contact information, is provided to them so that the transaction can take place.
  • We may also use your personal data, or permit selected third parties to use your personal data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post or email or telephone, in accordance with our obligations under applicable law. We do not disclose information about identifiable individuals to our advertisers, sponsors or our partners but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers, sponsors or our partners reach the kind of audience they want to target (for example, women in SW1).
  • We will not sell, share, transfer or rent the personal data collected on this Website other than as disclosed in this Policy.

4. International data transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff, operating outside the EEA, who work for us. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and applicable privacy legislation.

5. Cookies

We may obtain information about your general internet usage by using a ‘cookie’ – a small file which is stored on the hard drive of your device. It records information about your device, your browser and, in some cases, your preferences and browsing habits. They help us to improve the Website and to deliver a better and more personalised service. They enable us to:

  • estimate our audience size and usage pattern;
  • store information about your preferences, and so allow us to customise the Website according to your individual interests;
  • speed up your searches; and
  • recognise you when you return to the Website.

Our cookies fall into three broad categories:

  • Essential cookies: Used to identify members who have logged in;
  • Website information cookies: For the purposes of recording information about visitors to the website. This information is used to monitor the sites from which visitors arrived at the Website, to determine which pages and features within the Website are popular, and to deliver an improved service to visitors.
  • Third party cookies: Some pages within the Website may contain content embedded from third party websites, such as Fixtures Live, Facebook, Twitter, Youtube and others. These third parties may set their own cookies which, as noted above, are subject to the cookie policies of those third parties. We recommend that you review such policies separately.
    • You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. Instructions on how to do so will vary from browser to browser but you can find out more at www.aboutcookies.org.
    • Some features and functionality may be lost if you choose to disable cookies. Also, remember that you will have to adjust the cookie settings for each browser and device and you use to visit the Website.

6. Security

  • We use appropriate technical and organisational measures to protect your information. For example, your personal data held by us is subject to access restriction. Our employees must use password-protected log-in screens to gain entry to such restricted information. All employees are provided with training to help keep them up-to-date on our security and privacy practices.
  • Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data, but cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk.

7. Storage and accuracy of personal data

  • The accuracy of your personal data is important to us. If you change your email address or any of the other information we hold is inaccurate or out of date, please update the information when you log on to the Website.
  • We manage the Website from one central location that is located in the United Kingdom. By using the website, your personal data will be transferred to, and stored at that location.
  • Any personal data that are stored in hard copy will be kept in a secure location, and appropriate physical and organisational security measures will be applied.
  • We will hold your personal data within our systems for as long as you are a registered user. Upon cancellation of your registration, the information will be retained for as long as necessary and in any event for up to six years.

8. Direct marketing and your rights

  • You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us at office@lullabytrust.org.uk.
  • If you are an existing customer of the Website, we will only contact you by electronic means (email or SMS) with information about goods and services similar to those which were the subject of a previous sale to you or dealings with you.

9. Access to information

  • You have the right to access your personal data that we hold. Your right of access can be exercised in accordance with applicable privacy legislation.
  • You may request at any time a copy of the data we hold on you by sending an e-mail to office@lullabytrust.org.uk.

10. Changes to our Policy

If we decide to change this Policy, we will post those changes on the Website. You should review this Policy each time you use the Website, to ensure that you are familiar with its provisions.

11. Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Chief Executive of The Lullaby Trust, 11 Belgrave Road, London SW1V 1RB or email office@lullabytrust.org.uk