Privacy notice
Last Updated: Sep 2026
[DRAFT] This page needs legal and compliance review before publication. It is adapted from the privacy statement on the old site and is not approved for use.
Who we are
Charitytransfers.org is the corporate social responsibility division of Audere Solutions Ltd. We are bound by data protection legislation in each of the various jurisdictions in which we operate ("Applicable Data Protection Law") and we are committed to protecting your privacy. When we say "Audere", "we", "us" or "our" we mean Audere Solutions Limited.
Audere Solutions Ltd is a company registered in England and Wales, company number 09181148, whose registered office is at 97 Jermyn Street, London, SW1Y 6JE. Audere is authorised and regulated by the Financial Conduct Authority. Its Financial Services Register number is 707835.
About this notice
This notice is a "privacy notice" for the purposes of Applicable Data Protection Law, and in particular the UK GDPR and the Data Protection Act 2018 [CONFIRM: jurisdiction wording]. It is given by an Audere entity acting in its capacity as a data controller in relation to its collection and use of Personal Data.
Where Personal Data about you is collected and then used by Audere under this notice as a result of you engaging with us, we act as the data controller in respect of that Personal Data. Where Personal Data about you is provided by someone else, or is collected by Audere itself, this notice also applies to its collection and use.
This notice does not apply to the collection or use of Personal Data by Audere acting as a data processor, except to the extent that its terms, or some of them, are incorporated into a relevant processing agreement, either expressly or by reference.
In this notice, "those connected with you" means (a) your employees or other people who deal with us on your behalf, whether you are a client that is an individual, a corporate body or some other form of entity or organisation, or an investor in, or an owner of, a client, and (b) those people who represent other entities or organisations that we might deal with, such as advisers, regulators, suppliers or anyone else who makes any form of enquiry in relation to us or our services.
Please read this notice carefully to understand our practices regarding your Personal Data and how we will treat it. If you have any queries about anything in it, please contact our Data Protection Officer, whose contact details are at the end of this page.
The purpose of data protection
The purpose of data protection legislation is to protect the rights and privacy of individuals ("Data Subjects") in respect of the Processing of Personal Data concerning them.
"Personal Data" is any information relating to an identified or identifiable natural person, known as a data subject. A person is "identifiable" if he or she can be identified, directly or indirectly, not only by things such as a name or an identification number, but also by things such as location data or some factor specific to, for example, the physical, physiological or social identity of that person. More common examples of Personal Data include names, identification numbers, contact information, identity documents, medical records and photographic images.
"Processing" covers any activity involving Personal Data and includes such things as the collection, recording, storage, adaptation, use, disclosure and destruction of Personal Data.
Audere will Process Personal Data in accordance with Applicable Data Protection Law.
Our policies
We have policies and procedures that aim to ensure that all our staff, contractors and others that we work with, and who Process any Personal Data held by us or on our behalf, wherever in the world, are aware of and abide by their duties under Applicable Data Protection Law.
Audere abides by standards of data protection that are substantially the same as those set out in the UK GDPR and the Data Protection Act 2018 [CONFIRM: jurisdiction wording], which require, among other things, that Personal Data must be:
processed lawfully, fairly and in a transparent manner;
collected for lawful purposes that are clearly specified, and only further processed for compatible purposes;
relevant and limited to what is necessary for the purposes of the processing;
accurate and kept up to date, with inaccurate Personal Data being erased or rectified without delay;
kept for no longer than is necessary; and
processed in a secure manner, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Whose Personal Data we Process
Clients and potential clients
We have clients that are individuals and clients that are corporate bodies, including limited liability partnerships, government departments and agencies and other public bodies. Even where our clients are not themselves individuals, they will be represented by individuals, and they may be owned by individuals and invested in by individuals. As a result, we will inevitably Process Personal Data in the course of our relationships with those clients too.
As a potential client, and then, if applicable, as a client, the Personal Data that we Process will include personal and professional contact details (addresses, telephone numbers, email addresses), copy identity documents and proofs of address, copy professional and educational certificates, details of bank accounts or other payment details, and details of financial standing and investment objectives.
In addition, if you leave a voicemail message with us, that message may be Processed in a similar manner, and for the same or similar purposes, as email and postal correspondence from or concerning you.
Investors, legal and beneficial owners, settlors, protectors and beneficiaries
We deal with individuals and various types of organisation that are connected with clients, such as owners, investors and beneficiaries.
As a person connected with a potential client and, if applicable, then a client, the Personal Data that we Process about you will include personal and professional contact details (addresses, telephone numbers, email addresses), copy identity documents and proofs of address, copy professional and educational certificates, and data to facilitate tax information exchange.
In addition, if you leave a voicemail message with us, that message may be Processed in a similar manner, and for the same or similar purposes, as email and postal correspondence from or concerning you.
Other client-connected people: advisers and regulators
We also deal with organisations that provide professional advice or services to us or to our clients, those that supervise and regulate us and our clients, those that supply goods and services to us, and our past, present and, in the case of job applicants, future staff.
As an other client-connected person, the Personal Data that we Process about you will include personal and professional contact details (addresses, telephone numbers, email addresses) and, if you leave a voicemail message with us, that message may be Processed in a similar manner as email and postal correspondence.
Suppliers and potential suppliers
As a potential supplier, and then, if applicable, as a supplier, the Personal Data that we Process will include personal and professional contact details (addresses, telephone numbers, email addresses), documents and other proofs of standing and reputation, and details of bank accounts or other payment details.
In addition, if you leave a voicemail message with us, that message may be Processed in a similar manner, and for the same or similar purposes, as email and postal correspondence from or concerning you.
Potential employees
If you are an applicant for a job with us, the Personal Data that we Process about you will include:
your name, address and contact details, including telephone numbers and email addresses;
details of your qualifications, skills, experience and employment history;
information about your current level of remuneration, including entitlement to benefits;
whether or not you have a disability that we may need to make adjustments for during the recruitment process;
information about your entitlement to reside or work in the place where you have applied for a job; and
equal opportunity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or beliefs.
In addition, if you leave a voicemail message with us, that message may be Processed in a similar manner, and for the same or similar purposes, as email and postal correspondence from or concerning you.
If your application for a job with us is successful, our retention of your Personal Data will be governed by our separate policy on staff Personal Data, which will be made available to you by our Human Capital department as part of your becoming a member of staff.
Enquirers and visitors to our website
You may give us Personal Data by filling in a contact form on our website or by corresponding with us by email. In each case, the Personal Data that we Process will include personal and professional contact details (addresses, telephone numbers, email addresses) and, if you leave a voicemail message with us, that message may be Processed in a similar manner as email and postal correspondence. If you have stated contact preferences for service or jurisdiction updates, or for events that we may organise or participate in, we will also Process that information.
We will also automatically collect certain information each time you visit our website. This includes:
technical information, including the Internet Protocol (IP) address used to connect your computing device to the internet, your browser type and version, time zone setting, operating system and platform;
information about your visit, which may include the pages viewed and page response times; and
your country of location, by reference to a look-up of your IP address against public sources.
Our website also uses cookies and similar technologies to collect and store certain information about your interaction with it. For more information, see our cookie notice.
Lawful bases we rely on
The sections below state, for each purpose, the basis on which we Process Personal Data. In summary, we rely on performance of a contract with you, compliance with a legal obligation, our legitimate interests, and, in the limited cases described in this notice, your consent. [CONFIRM: added summary; the source states the lawful basis within each purpose rather than as a list, and no basis has been added or changed]
How we use the Personal Data we Process
Clients and potential clients
As a potential client, we will Process Personal Data about you and those connected with you for the purpose of carrying out our business and in order to:
respond, in our legitimate interests, to your enquiries about our services and other requests;
carry out due diligence or other know-your-customer, anti-money laundering, counter-terrorist financing or anti-bribery checks, in accordance with legal obligations to which we are subject or in our legitimate interests to satisfy our regulatory obligations and our own risk management procedures;
conduct checks concerning creditworthiness and standing before entering into an agreement with you;
take steps, in our legitimate interests, to prevent, detect or investigate crime, fraud, misconduct or any unlawful action or omission, whether or not relating to your enquiry and whether or not there is any suspicion of illegality;
enter into an agreement with you regarding the provision of services;
verify and carry out financial transactions in relation to the provision of the services under the agreement with you;
manage our infrastructure and business operations and comply with policies and procedures that may be required by law, or where necessary for our legitimate interest to satisfy other applicable industry regulation, guidelines or notices, or that may have been put in place by us, including those relating to regulatory review and oversight, internal or external auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity; and
correspond with you concerning our present and future services and relevant news and service updates, with your consent where required by law or otherwise in our legitimate interests, provided these interests do not override your right to object to such communications.
If you become a client, we will continue to Process Personal Data about you for such of the purposes described above as continue to be relevant. In addition, we will Process Personal Data about you and those connected with you regarding the ongoing provision of services, as described below.
If you do not become a client, we will only keep Personal Data that you have made available to us if it is necessary for us to keep it for legitimate business purposes, or as we are required to keep it by law or regulation.
If you do become a client, we will need to Process Personal Data under the agreement entered into between you and us in order to:
provide you with services and to administer and manage our relationship with you;
carry out your instructions and respond to enquiries made by you;
recover any fees owed to us under our agreement with you;
under our legal obligations to:
collect and use certain information, for example with regard to the ownership of assets;
carry out ongoing due diligence or other know-your-customer, anti-money laundering, counter-terrorist financing or anti-bribery checks;
comply with other applicable law and regulations in the various jurisdictions in which we operate;
or in our legitimate interests:
to manage our infrastructure and business and to further our business interests;
to comply with policies and procedures under applicable professional regulation, guidelines or notices, or that may have been put in place by us, including those relating to regulatory review and oversight, risk management, internal or external auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity; and
for other purposes which we may notify you of from time to time, obtaining your consent where necessary.
Investors, legal and beneficial owners, settlors, protectors and beneficiaries
If you are an investor in, or the legal or beneficial owner of, a client that is a corporate body, a partnership or an unincorporated association or body, or if you are a settlor, protector or beneficiary of a trust, or a founder, council member or beneficiary of a foundation, you may be a person connected with a potential client or client. As such, we will Process Personal Data about you and those connected with you in order:
to provide services to the client with which you are connected;
under our legal obligations to:
collect and use certain information, for example with regard to the ownership of assets;
carry out ongoing due diligence or other know-your-customer, anti-money laundering, counter-terrorist financing or anti-bribery checks;
comply with other applicable law and regulations in the various jurisdictions in which we operate;
or in our legitimate interests:
to manage our infrastructure and business and to further our business interests;
to comply with policies and procedures under applicable professional regulation, guidelines or notices, or that may have been put in place by us, including those relating to regulatory review and oversight, risk management, internal or external auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity; and
for other purposes which we may notify you of from time to time, obtaining your consent where necessary.
Other client-connected people: advisers and regulators
If you are a person connected with a client or a potential client by reason of being the accountant, lawyer, banker or other adviser to that client or potential client, or if you are a person who carries out any supervisory or regulatory function in any jurisdiction in connection with Audere or a client or potential client, we may Process Personal Data about you and those connected with you for the purpose of our legitimate interest in carrying out our business, including in providing services to the client or potential client with which you are connected.
Suppliers and potential suppliers
As a potential supplier, we will Process Personal Data about you and those connected with you for the purpose of entering into and receiving services under a contract with you relevant to carrying out our business, and in order to:
respond to your enquiries about supplying goods or services to us;
conduct checks concerning standing and reputation;
enter into an agreement with you regarding the provision of services; and
correspond with you concerning your present and future goods or services.
If you do become a supplier of Audere, we will need to Process Personal Data in order to:
administer and manage our relationship with you;
respond to enquiries made by you;
carry out ongoing checks in accordance with legal or regulatory obligations and our own risk management procedures;
conduct and verify ongoing standing and reputation checks;
pay for goods and services received;
comply with legal or regulatory obligations, for example with regard to a regulator's outsourcing policy; and
for other purposes which we may notify you of from time to time, obtaining your consent where necessary.
Potential employees
If you are an applicant for a job with us, we will Process Personal Data about you in our legitimate interests, in order to assess your application and to advance that application through our recruitment processes. This includes making details of your application, including Personal Data, available to relevant members of our management and of our Human Capital department, and complying with policies and procedures under applicable professional regulation, guidelines or notices, or that may have been put in place by us, in relation to staff and recruitment.
Enquirers and visitors to our website
If you have completed a form on our website, making a new business enquiry or asking a general question, and indicating the services or jurisdictions you are interested in, we will Process Personal Data about you for the purpose of our legitimate interest in responding to your enquiry or request for information.
Likewise, if you have contacted our marketing team by email, either via the website or independently, or otherwise with a media enquiry, we will Process Personal Data about you on the same grounds in order to respond to your enquiry or request for information.
Further, if you leave a voicemail message with us, that message may be Processed in a similar manner, and for the same or similar purposes, as email and postal correspondence from or concerning you.
If you or someone who works for you has given us a business card at a conference or a business meeting, we will use the contact details on the card in connection with the specific purpose for which it was provided. Where the card is provided for the specific purpose of requesting our promotional update communications, we may first, where permitted by Applicable Data Protection Law, send an email promptly after receiving the business card, to confirm the request, clarify its scope and allow you to complete contact preferences.
We use information about visitors to our website in our legitimate interests for internal operations, to ensure that content is presented in the most effective manner for you and your computer, and to keep our website safe and secure.
Promotional updates and communications
Where permitted by law, or otherwise with your prior consent, we will use Personal Data to provide you with promotional update communications about us or our services, and we may also invite you to tell us what your areas of interest are.
If you are on one of our contact lists, you can check and update your contact details, change your preferences or unsubscribe at any time, either by following the links at the end of all our marketing and promotional update communications or by contacting us through our website. We will ensure that your details and preferences, or your request to unsubscribe, are dealt with promptly.
Even if you tell us that you do not want to receive marketing or promotional update communications from us, we may still have the right to Process Personal Data for the purposes of providing the services, and in such cases we will continue to Process that Personal Data for those purposes.
We do not sell or otherwise pass on your contact details to any third party outside Audere for marketing purposes.
Who we share Personal Data with
We may share Personal Data with:
business partners, suppliers, affiliates, agents and sub-contractors, for the performance of any agreement we enter into with you. They may assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing IT and other support services, or in other tasks from time to time. These third parties will only use your information to the extent necessary to perform their functions.
credit reference agencies, for the purpose of assessing your credit standing where this is a condition of us entering into a contract with you.
external networking sites. Our website contains plug-ins to such sites. If you are a member of one of those social networking providers and you are logged in while visiting our website, the relevant social network provider may assign information to your social media account. By interacting with one of the plug-ins on our website by clicking the interaction button, information that you visited our site may be shared with the relevant social networking provider and held as part of your separate social networking user account. You should read the privacy policy of your social networking provider for further information about their collection and use of your Personal Data.
[CONFIRM: whether the rebuilt site carries any social networking plug-ins, or only plain links]
We will also disclose or share your Personal Data where we are under a duty to do so in order to comply with any legal obligation, in order to enforce or apply our terms of supply and other agreements with you, or to protect the rights, property or safety of Audere, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Security
We have taken steps to apply appropriate technical and organisational measures to prevent the unauthorised or unlawful Processing of Personal Data, and the accidental loss or destruction of, or damage to, Personal Data. This includes, but is not limited to, using properly configured and maintained firewalls, encryption, and anti-virus and anti-malware protection on servers and laptops and PCs, with emails scanned for viruses and spam.
Our staff have an obligation to ensure that appropriate security measures are implemented at all times, in accordance with the guidance set out in our information security and data protection policies and procedures.
As a general rule, Audere's IT tools and applications, such as the email system and the data, client and document management systems, are administered by Audere's IT team in the UK.
How long we keep Personal Data
Audere has retention policies in place to meet regulatory requirements and client obligations. We retain Personal Data for the duration of the services that we provide, as necessary to meet our contractual obligations to you, to identify issues, or to issue and resolve legal proceedings.
We also retain Personal Data beyond the duration of the services that we provide, as necessary to meet our legal and regulatory obligations to retain such information under applicable law. We may also retain aggregate information beyond this time for statistical analysis and research purposes and to help us improve our services. Old media, such as PC and server disks and tapes, are stored and then destroyed using a reputable specialist organisation.
Retention periods are kept under review. There may be some cases in which we are obliged to delete Personal Data we Process, such as the data having been Processed in breach of Applicable Data Protection Law, or to comply with a legal obligation to delete it.
In other cases, there may be no specific time limit applicable to the retention of particular Personal Data. In determining how long particular Personal Data will be retained for, we will use criteria including whether:
the data is no longer necessary for the purpose in relation to which it was collected;
the data can, if required, be collected again without undue delay or difficulty.
We will delete any Personal Data that is no longer required, and will do so in an appropriate and secure manner.
Withdrawing your consent
We will not, as a general rule, seek or rely on your consent to Process Personal Data about you. However, to the extent that we do on occasion rely on your consent in respect of particular Personal Data, we will cease Processing that Personal Data by deleting it if you withdraw that consent at any time.
Likewise, where we rely on your consent to Process special category Personal Data, we will cease Processing that special category Personal Data by deleting it if you withdraw that consent at any time.
Where, for example, we Process your Personal Data with your consent in order to send you promotional update communications about us or our services, if you withdraw that consent we will not be able to send you such communications.
Objecting to our Processing
You have the right to object to the Processing of Personal Data by us on the grounds of performance of a legal task or our legitimate interest, but that objection must be on grounds relating to your particular situation. In such circumstances, we will stop Processing the Personal Data in question unless:
we can demonstrate compelling legitimate grounds for the Processing which override the interests, rights and freedoms of the individual; or
the Processing is for the establishment, exercise or defence of legal claims.
If you do object to the Processing of your Personal Data by us and, as a result, we stop Processing it, we may not be able to continue to provide services to you in a particular manner or at all, and we may, as a result, need to terminate our service agreement with you.
If, as an unsuccessful job applicant, you ask us to retain your Personal Data but you later change your mind and ask us to delete it, we will not be able to refer to your original application should a potentially suitable vacancy subsequently occur.
Where we store Personal Data
Audere stores data in the UK, on our servers at its physically secured premises.
All premises and data centres used by Audere for its IT infrastructure are secured by strong access control systems. Only a limited number of staff members and, on occasion, reputable and trusted third party IT suppliers that are subject to appropriate data protection and confidentiality obligations, have supervised physical or remote access to Audere's IT infrastructure and systems.
Certain clients have portals and document repositories provided by Audere facilities, for controlled secure access to documents and information to be shared between Audere and the client in question, and through which Audere and the client can communicate. Such portals and document repositories are operated by Audere in conjunction with third party service providers, and client data is held, and backed up, on Audere servers hosted in independently certified third party data centres.
Audere's customer relationship management system is provided by Salesforce, an internationally recognised service provider. Client contact details (addresses, telephone numbers, email addresses) are held, and backed up, in the cloud on servers hosted in countries on the European Commission's list of countries ensuring an adequate level of protection for the rights and freedoms of Data Subjects. [CONFIRM: jurisdiction wording]
International transfers
In certain cases, Personal Data may be transferred to other countries where Audere maintains operations, or where its service providers are located. Where these transfers are to be made outside the European Union, we will make sure that the recipient of the Personal Data has provided adequate safeguards, in accordance with the requirements of the GDPR, by, for example, entering into appropriate European Commission-approved standard contractual clauses relevant to transfers between data controllers, or between a data controller and a data processor. [CONFIRM: jurisdiction wording]
In the case of transfers of Personal Data among members of Audere, all such members are subject to the internal data protection policies and procedures of Audere, which are based on GDPR compliance. [CONFIRM: jurisdiction wording]
In the case of transfers of Personal Data to third parties located in a country that is not subject to an adequacy decision by the European Commission, we will only transfer your Personal Data to third parties that have been approved for use by Audere following due diligence, and in each case provided that such third parties are the subject of contractual arrangements with us imposing, among other things, obligations on the third party to ensure that appropriate technical and organisational measures are implemented by it at all times to prevent the unauthorised or unlawful Processing of Personal Data, and the accidental loss or destruction of, or damage to, Personal Data, again consistent with the obligations set out in the European Commission-approved standard contractual clauses. [CONFIRM: jurisdiction wording]
Your rights
You have a number of rights under the UK GDPR and the Data Protection Act 2018 [CONFIRM: jurisdiction wording] in relation to your Personal Data. You have the right, in certain circumstances, to:
have access to your Personal Data by making a subject access request;
have your Personal Data corrected if it is wrong or, in certain circumstances, to have it deleted;
have the Processing of your Personal Data restricted, while we verify or investigate your concerns with this information, for example;
object to the further Processing of your Personal Data in certain circumstances, including the right to object to marketing;
request that we move the Personal Data you have provided elsewhere, known as data portability;
withdraw any consent that you have given us, if we are Processing your Personal Data only because you have given that consent; and
not have your Personal Data automatically Processed.
[CONFIRM: intended meaning of this right, which appears to concern automated decision-making and profiling]
Cookies
Our website uses cookies and similar technologies. Our cookie notice explains which cookies we use, what they do, and how you can accept or decline the ones that are not essential.
How to contact us
If you wish to exercise any of your rights in relation to your Personal Data, if you have any complaint about the way in which we Process Personal Data, or if you require any further information about this notice or its contents, please contact us in the first instance:
Data Protection Officer / Data Privacy Manager
Email: t.swift@auderesolutions.com
[CONFIRM: current named officer and mailbox]Post: 33 Cannon Street, London, EC4M 5SB
[CONFIRM: the old privacy statement gives this address, while the registered office is 97 Jermyn Street, London, SW1Y 6JE]Telephone: +44 (0) 203 5984 992
[CONFIRM: one telephone number for the site]
Complaints to a data protection regulator
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority in the jurisdiction in which we provide services to you.
The contact details for the data protection regulator in the United Kingdom are:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone: 0303 123 1113 (local rate). Online: https://ico.org.uk/global/contact-us/email/
[CONFIRM: whether regulators in any other jurisdiction should be listed, as the old statement referred to the regulators in all jurisdictions in which Audere operates but named only the United Kingdom]
Complaints about our service, rather than about personal data, are handled under our complaints procedure.
Changes to this notice
We review our policies and procedures regularly and we reserve the right to amend the terms of this notice from time to time at our absolute discretion. Any amended notice will be posted on our website, and you are encouraged to visit our website from time to time to ensure that you are aware of our latest policies in relation to the protection of Personal Data.