Privacy Policy

Operation Eyesight Universal is an international development organization made up of different legal entities across several continents, including Operation Eyesight UK Limited (company number: 06818832), Operation Eyesight Canada (charitable registration number: 119068955 RR 0001) and Operation Eyesight USA (charitable registration number: 20-2682468). Each company within the Operation Eyesight Universal group shall be referred to collectively as Operation Eyesight Universal for the purpose of this privacy policy. 

This privacy policy is issued on behalf of Operation Eyesight Universal, so where we mention “we”, “us” or “our”, we are referring to the relevant company in Operation Eyesight Universal that is responsible for processing your personal data.  
This privacy policy describes how we collect, use and look after your personal data. While this policy was developed for the purposes of the UK data protection laws, it applies to all companies that make up Operation Eyesight Universal.  
In respect of our website, please note that it: 

is not intended for children and we do not knowingly collect data relating to children; and 
may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Contacting Us

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us via our Privacy Officer by email at privacyofficer@operationeyesight.com or by telephone at 1-800-585-8265 (toll-free in Canada and the United States).

It is important that the personal data we hold about you is accurate and current. Please let us know, using the contact details above, if you change any of the personal data that we hold about you.

You have the right to make a complaint at any time to the relevant regulator for data protection issues. Where your complaint relates to Operation Eyesight UK Limited, you should get in touch with the Information Commissioner’s Office (ICO). Where your complaint relates to Operation Eyesight Canada, you should get in touch with the applicable Canadian regulator which will either be the Office of the Information Commissioner of Canada, the Office of the Information and Privacy Commissioner of Alberta, the Office of the Information and Privacy Commissioner for British Columbia or the Québec Access to Information Commission. Where your complaint relates to Operation Eyesight USA, you should get in touch with the Department of State’s Privacy Office. We would, however, appreciate the chance to deal with your concerns before you approach the relevant regulator, so please contact us in the first instance using the contact details set out above.

The Data We Collect About You

For your information, personal data (also known as personal information), means any information about an identifiable individual.

We may collect, use, store and transfer different kinds of personal data about you. These can be separated into the following different categories, though please note that not all these categories may be applicable to you:

Identity Data includes first name, maiden name, last name, title, gender and your relationship with other donors or prospective donors (if you are related to or otherwise connected with any of our other donors or prospective donors).
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Financial Data includes bank account and payment card details.
Transaction Data includes details about previous donations you have made or events you have attended.
Technical Data includes internet protocol (IP) address, browser type and version, universally unique identifiers, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data includes donations made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under UK law as it does not directly or indirectly reveal your identity. For example, we may aggregate your Contact Data and Transaction Data to calculate where our most generous donors are located. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic and biometric data). We also do not collect any information about criminal convictions and offences.

How is Your Personal Data Collected

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your Identity Data, Contact Data, Financial Data, Profile Data and Marketing Data by filling in our donation forms, in face-to-face meetings or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

inquire about donating
donate
register as a donor
sign up to attend one of our events
subscribe to receive our marketing communications and resources
take part in one of our surveys
give us feedback; or
contact us by any means.

Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy here for further details.

Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:

Identity Data and Contact Data from:

data brokers or aggregators such as iWave and LinkedIn, which may be based in or outside the UK; and
publicly available sources such as Companies House and the Electoral Register, based in the UK.

Technical Data from:

analytics providers such as Google, which may be based outside the UK;
advertising networks such as Bell Media, Meta Platforms, Inc., X and Google Ads, which may be based outside the UK; and
search information providers such as Google, Microsoft, Vimeo and Bing which may be based outside the UK.

We do not intend the above lists to be exhaustive but rather provide you with some examples of the types of third parties we might receive personal data from.  

We collect personal data from the above third parties and/or publicly available sources to gain insights into our existing donors and prospective donors. This may include wealth screening information or other general publicly available information. We use such information gathered by these means, alongside the other personal data we hold about you, to assist us with building a profile about you, and this may be referred to as ‘profiling’ or ‘screening’. We use this profile to help us better understand our existing donors and prospective donors, as well as their needs and preferences so that we can improve how we interact with and inform them.

How We Use Your Personal Data

We will only use your personal data where we have a lawful basis to do so. The most common lawful bases we rely on are:

where you have given clear and positive consent for us to process your personal data for a specific purpose; and/or
where it is necessary for us to conduct our business (known as our legitimate interests). For example, this may be so we can process your donations, manage our relationship with you and ensure we provide you the best possible service. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); and/or
where we need to comply with a legal obligation that we are subject to.

Please refer to our table below to understand the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing, including basis of legitimate interest
To register you as a donor or register your interest as a prospective donor which will include:   adding you to our donor database; contacting you to help you through the registration process.	Identity Contact Transaction Profile Marketing	Necessary for our legitimate interests of: ensuring our records are up to date; and securing more donors to further advance our charitable purposes and objectives.
To process your donation and, where applicable, claim tax relief or provide tax receipts in respect of your donation	Financial Identity Contact	Necessary of our legitimate interests of collecting donations to enable us to continue and further advance our charitable purposes and objectives. Necessary to comply with a legal obligation.
To create a profile of you as a donor or potential donor which may be used to improve how we interact with you and inform you of updates with respect to the charity, our events and our news	Identity Contact Transaction Technical Profile Usage	Necessary for our legitimate interests of understanding more about our donors and potential donors which, in turn, enables us to build relationships and secure future donations.
To manage our relationship with you which will include: notifying you about changes to our terms or polices; and asking you to leave a review for feedback or take a survey	Identity Contact	Necessary to comply with a legal obligation  Necessary for our legitimate interests of understanding and analysing what our donors think about us and how they use our service so that we can further grow our business
To manage our relationship with you where you are a regular donor	Identity Contact Transaction Profile Usage Marketing	Necessary for our legitimate interests of identifying those regular and/or generous donors so that we can analyse and understand their donation habits and ensure they receive the best possible experience.
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests in running our business, the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.  Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you on our site and third-party sites (including your social media accounts) and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Technical Usage Marketing	In respect of the delivery of advertisements, your consent  In respect of understanding the effectiveness of advertising, necessary for our legitimate interests to study how customers use and interact with our services so we can develop them and grow our business
To use data analytics to improve our website, services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests in defining types of donors, keeping our website updated and relevant, to develop our business and to inform our marketing strategy
To provide updates and make suggestions and recommendations to you about our charity and events that may be of interest to you	Identity Contact Technical Usage Profile Marketing	Where such communications are made by email, social media messaging, phone, SMS or other electronic message, your consent.  In all other cases, necessary for our legitimate interests to engage our prospective donors and donors so that we can develop our business and expand our charitable efforts

Marketing

Promotional offers from us: We may use your Identity, Contact, Transaction, Technical, Usage and Profile Data to create a profile of you and form a view on what we think may be of interest to you. This is how we decide which communications, information or events may be relevant for you.

Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Disclosures of Your Personal Data

Our website and the servers that make this website available worldwide are located in the United States. Any information you provide in subscribing to or visiting our website will be transferred to the United States. Please see the “Transfers Outside of the UK (Relevant to our UK Activities and UK Donors)” section below for further information if you are a UK donor.

We may share your personal data with the parties set out below for the purposes set out in the table above:

Internally within Operation Eyesight Universal.
Externally to third parties outside of our group of companies such as:
Externally to third parties outside of our group of companies such as:
- our service providers (who will only process personal data in accordance with our instructions unless you are notified otherwise), including:
Our payment providers who process donations on our behalf, including:
- Authorize.net, based in the United States;
- Bambora, based in the United States;
- Benevity, based in Canada;
- CanadaHelps, based in Canada;
- Charitable Impact, based in Canada;
- CIBC Cash Management Online, based in Canada;
- Elavon, based in the United States;
- Nintex, based in the United States;
- PayPal, based in Canada; and
- Stripe, based in the United States.
our professional advisers including lawyers, bankers, auditors and insurers based in any of the countries where Operation Eyesight Universal operates and which provide us consultancy, banking, legal, insurance and accounting services;
the UK HM Revenue & Customs, the Canada Revenue Agency, the Provincial and Federal Commissions for Canada and the US Internal Revenue Service for the purpose of claiming tax relief on donations, submitting tax receipts in relation to donations and such other regulatory requirements that we must meet from time to time;
the UK Information Commissioner, the UK Charity Commission, the applicable Canadian regulator which will either be the Office of the Information Commissioner of Canada, the Office of the Information and Privacy Commissioner of Alberta, the Office of the Information and Privacy Commissioner for British Columbia or the Québec Access to Information Commission, the US Department of State’s Privacy Office and such other regulators and authorities based in any of the countries that Operation Eyesight Universal operates in who require reporting of processing activities in certain circumstances; and/or
any third parties to whom we may choose to sell, transfer or merge parts of our business or our assets with. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Online Donations

We use a service provider (Fundraise Up) as an online donation platform. All donation data collected is subject to the provisions of the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), and other applicable privacy laws. Non-Personal Information that is collected remains anonymous or non-personally identifiable. All Personally Identifiable Information (PII) is encrypted. Financial information, such as banking information or credit card number, name, CVV code, or expiration date, is collected and stored by a third-party payment processor. Financial information is not stored by Fundraise Up.

The Fundraise Up platform features functionality, known as machine learning, to make suggestions that are appropriate and relevant to you, such as the donation amount and whether to give you an option to cover the transaction costs. This is based on analysis of publicly available data related to your location, browser type and device, plus your website activity and previous donations made to Operation Eyesight through the Fundraise Up platform. This information is only ever used anonymously and in ways that cannot identify any individual.

Our California Do Not Track Notice

You may be able to change your cookie preferences via your browser settings. Please visit your browser’s help section for assistance with turning on notifications regarding cookies, or disabling cookies through your browser.

Transfers Outside of the UK (Relevant to our UK Activities and UK Donors)

Operation Eyesight UK Limited may share your personal data within Operation Eyesight Universal.

This will involve transferring your data outside the UK. As explained above, many of our external third parties are based outside the UK and our website is hosted in the United States and so such processing of your personal data will also involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed by UK data protection laws to provide an adequate level of protection for personal data; or
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business with whom the Californian has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of the information disclosure provided by us pursuant to this provision, please contact us via our Privacy Officer by email at privacyofficer@operationeyesight.com or by telephone at 1-800-585-8265 (toll-free in Canada and the United States).

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements. 

Details of retention periods for different aspects of your personal data are available in our retention schedule which you can request from us by contacting us. 

In some circumstances you may ask us to delete your data and if you wish to do so, please refer to the information we have set out below on your legal rights.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the following:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which you will be notified of, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your individual situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it because you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used and machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us and note the following before doing so:

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Changes to this Policy

We keep our privacy policy under regular review, and we may change this policy from time to time to reflect how we are processing your personal data. Please review this policy regularly to ensure you are kept updated on any changes we make. For your information, this version was last updated in May 2025.