UPDATED PRIVACY NOTICE (INCLUDING AFFILIATE MARKETING & TRACKING)

Association for Families of Independent Schooling (AFIS CIC) Company number: 16817786

1. Introduction

Welcome to the Privacy Notice of the Association for Families of Independent Schooling (AFIS CIC) (“AFIS”, “we”, “us”, “our”).

We respect your privacy and are committed to protecting your personal data. This Notice explains how we collect, use, and safeguard your information when you use our website, take part in our membership services, or interact with us.

It has been updated to reflect our participation in affiliate marketing programmes, which allow AFIS to fund its work through commission earned when users click links to certain retailers or partners.

2. Important Information and Who We Are

AFIS CIC is a not-for-profit Community Interest Company. We act as the “data controller” of your information.

• Data Protection Officer (DPO)
• Name: Michelle Daniells
• Email (data queries): michelle@afis.co.uk
• General queries: hello@afis.org.uk
• Postal address: 12 Fratton Road, Portsmouth, Hampshire, PO1 5BX, UK

3. Changes to This Notice

The most recent update date is shown at the top. This Notice may be updated if our practices or legal obligations change.

Please notify us if your personal information changes.

4. Third-Party Links

Our Site contains links to third-party websites, including affiliate partners. When you click such links, third parties may set cookies or track that AFIS referred you. We recommend reviewing the privacy notices of those third-party websites.

5. The Data We Collect About You

We collect the following categories of data:

5.1 Identity & Contact Data

• Name
• Address
• Email address
• Telephone number
• Date of birth (where relevant for membership categories)

5.2 Membership & Financial Data

• Membership records
• Transactions you make directly with AFIS (e.g., events, training, fundraising activities)
• Donation information

(We do not store full card or bank details.)

5.3 Technical & Usage Data

Collected through cookies, analytics, and tracking technologies:

• IP address
• Browser and device information
• Website usage patterns
• Cookie IDs
• Affiliate tracking codes (when you click affiliate links)

5.4 Affiliate Tracking Data (Option A scope)

When you click an affiliate link:

• A cookie or tracking URL records that AFIS referred traffic to a partner
• The affiliate network may send AFIS limited information, such as:
• – that a purchase occurred
• – the commission due
• – the date/time of referral
• – a pseudonymous or anonymous identifier

AFIS does not:

• receive your individual purchase details
• receive your full transaction data
• receive detailed order information
• investigate untracked purchases or engage in cashback-style dispute processes

5.5 Profile & Preferences Data

• Interests and preferences
• Survey responses
• Marketing preferences

5.6 Aggregated Data

We generate anonymised analytics to understand trends and improve our services

5.7 Special Category Data

We do not normally collect this data unless explicitly provided for accessibility or support needs, and only with your consent.

6. How We Collect Personal Data

Directly from you:

• Becoming a member
• Contacting us
• Filling in forms
• Registering for events
• Taking part in surveys
• Subscribing to communications

Automatically:

• Through cookies, web beacons, analytics tools
• Through affiliate tracking when clicking partner links

From third parties:

• Event or payment platforms
• Analytics providers (e.g., Google Analytics)
• Affiliate networks (limited attribution data only)

7. How We Use Your Personal Data

We only use your personal data when lawful.

7.1 Lawful Bases We Rely On

• Contract – delivering membership services
• Legitimate Interests – running and improving AFIS, promoting our work, operating affiliate tracking
• Consent – sending marketing emails or surveys
• Legal Obligation – tax, company, and financial record-keeping

8. Purposes for Which We Use Your Data

8.1 To provide membership services

• Access to information, advocacy, events, and resources

Lawful basis: Contract; Legitimate Interests

8.2 To operate affiliate marketing programmes

This includes:

• Embedding affiliate links on the AFIS website
• Allowing affiliate networks to track referrals
• Receiving limited referral reports to support AFIS income

We do not receive full purchase data about you.

Lawful basis: Legitimate Interests

Legitimate interest: Generating income to support AFIS’s not-for-profit operations while minimising data processing.

8.3 To manage our relationship with you

• Updating records
• Sharing important notices
• Responding to enquiries

Lawful basis: Contract; Legitimate Interests; Legal Obligation

8.4 To improve our website and services

• Analytics
• Troubleshooting
• Service development
• Security monitoring

Lawful basis: Legitimate Interests

8.5 To conduct research and surveys

• Understanding member needs
• Improving AFIS’s services
• Publishing anonymous insights

Lawful basis: Consent; Legitimate Interests

8.6 To send marketing communications

• With your consent, OR
• Under the PECR “soft opt-in” for existing members

Lawful basis: Consent; Legitimate Interests Opt-out at any time.

9. Marketing and Opting Out

We never sell your data.

You may opt out using the link in our emails or by contacting us.

10. Disclosures of Your Personal Data

We may share data with:

• IT and cloud service providers
• Email and CRM platforms
• Analytics providers
• Affiliate networks (for referral tracking only)
• Professional advisers
• Regulators (if legally required)

Third parties only process your data following AFIS’s instructions.

11. International Transfers

Where third-party processors store data outside the UK, we implement appropriate safeguards such as Standard Contractual Clauses.

12. Data Security

We use technical and organisational measures to protect your information, including:

• Encryption
• Access controls
• Secure hosted systems
• Confidential disposal methods

13. Data Retention

We retain data only as long as needed.

Examples:

• Membership applications: 2 years after last activity
• Market research responses: 2 years
• Email correspondence: archive after 6 months
• Financial records: 6 years (legal)
• Technical/analytics data: as per cookie policy

Affiliate tracking cookies are retained according to the third-party provider’s timeframe.

14. Your Rights

You may request:

• Access
• Correction
• Erasure
• Restriction
• Objection
• Data portability
• Withdrawal of consent

We respond within one month.

15. How to Exercise Your Rights

Contact our DPO. We may verify your identity before responding.

16. Complaints

You can raise concerns with us or with the Information Commissioner’s Office (ICO):

www.ico.org.uk/make-a-complaint

0303 123 1113