Privacy Policy
The Primrose Trust — www.primrosetrust.org
Last updated: 17th June 2026
1. Introduction
The Primrose Trust (“the Trust”, “we”, “us”, “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store and protect personal information when you visit our website, apply for a grant, or otherwise get in touch with us.
This policy is written in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Who we are
The Primrose Trust is a charitable trust, registered with the Charity Commission for Northern Ireland (registered number NIC102734) and recognised as a charity by HMRC (reference number NI00468).
Registered office: 3 Benham Chase, Stockcross, Newbury, RG20 8LQ
For the purposes of data protection law, The Primrose Trust is the data controller of personal information processed through this website.
If you have any questions about this policy or how we handle your personal information, please contact us:
3. What personal information we collect
a) When you apply for a grant
If you complete our online Grant Application Form, we collect:
- Your name and the name of the Chair of your organisation
- Your email address and telephone number
- Your organisation’s name, address, aims, governance and funding information
- Details of your proposed project, including any images you upload
- Financial information relating to your project and your organisation, including past financial history
This information relates primarily to your organisation, but it includes personal information about the named individuals (such as the contact person and Chair) who represent it.
b) When you use “Save and Continue Later”
If you choose to save a partially completed application, we collect your email address so that we can send you a secure link to resume your application. This link expires automatically after 72 hours.
c) When you contact us
If you email or write to us directly, we will collect your name, contact details and the content of your message.
d) Automatically, through cookies
Our website uses Google Analytics to help us understand how visitors use our site. This involves the use of cookies. Please see our Cookie Policy for full details and to manage your preferences. Analytics cookies are only set with your consent.
4. How and why we use your information
We use the personal information we collect for the following purposes:
- To assess and process grant applications, including communicating with you about your application
- To maintain a record of grants awarded and applications received, for governance, accountability and historical reference
- To verify the information provided in an application, where necessary
- To respond to general enquiries
- To understand how our website is used and to improve it (where you have consented to analytics cookies)
- To comply with our legal and regulatory obligations as a registered charity
5. Our lawful basis for processing your information
Under UK GDPR, we rely on the following lawful bases:
- Legitimate interests: processing grant applications, assessing eligibility and maintaining records of our charitable activities are necessary for us to carry out our charitable purposes. We have considered that this processing does not unduly impact your rights and freedoms.
- Consent: where you have given specific consent, for example to receive analytics cookies, or where you provide additional information voluntarily.
- Legal obligation: where we are required to retain or disclose information to comply with charity law, tax law or other legal requirements.
We do not use your personal information for any automated decision-making or profiling.
6. Who we share your information with
We may share your personal information with:
- Our Trustees and any staff or volunteers involved in assessing grant applications
- Service providers who help us run our website and process applications, including our website hosting provider and email service provider
- Google, in connection with Google Analytics and Google reCAPTCHA (used to protect our application form from automated abuse). Google may process this information outside the UK; Google participates in appropriate safeguards including Standard Contractual Clauses
- Regulatory or legal authorities, where required by law
We do not sell or rent your personal information to third parties, and we do not share it for marketing purposes.
7. International transfers
Some of the third-party services we use (such as Google) may store or process information outside the UK and European Economic Area (EEA). Where this happens, we ensure appropriate safeguards are in place, such as the UK’s International Data Transfer Agreement or Standard Contractual Clauses, to protect your information to UK GDPR standards.
8. How long we keep your information
- Completed grant applications (whether successful or unsuccessful): retained indefinitely as part of the Trust’s permanent records, to maintain a historical record of our grant-making activity, support accountability to the Charity Commission and HMRC, and assist with any future applications from the same organisation.
- Partial applications that are never completed: if an application is started but not submitted, and is not resumed within 90 days, the partial record — including any uploaded files and resume links — will be automatically and permanently deleted.
- Resume links: deleted automatically once used, or after 72 hours, whichever is sooner.
- General correspondence: retained for as long as necessary to deal with your enquiry, and in line with our standard record-keeping practices.
If you would like us to delete personal information we hold about you sooner, please see “Your rights” below — though for completed applications, we may need to retain certain information to meet our legal and charitable record-keeping obligations.
9. How we protect your information
We take appropriate technical and organisational measures to protect your personal information, including:
- Restricting access to application data to authorised Trustees and administrators only
- Storing uploaded files in a protected location that cannot be accessed directly via the website
- Using secure, time-limited links for the Save and Continue Later feature
- Using industry-standard form protection (Google reCAPTCHA) to prevent automated abuse
No method of online transmission or storage is completely secure, but we work to protect your information to a high standard.
10. Your rights
Under UK GDPR, you have the right to:
- Access the personal information we hold about you
- Request that we correct inaccurate information
- Request that we delete your information, in certain circumstances
- Request that we restrict how we use your information
- Object to our use of your information, where we rely on legitimate interests
- Request a copy of your information in a portable format
- Withdraw consent at any time, where we rely on consent (for example, analytics cookies)
To exercise any of these rights, please contact us at mail@primrosetrust.org. We will respond within one month, as required by law.
If you are unhappy with how we have handled your personal information, you have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator, at ico.org.uk or by calling 0303 123 1113.
11. Cookies
Our website uses cookies, including Google Analytics, to understand how the site is used. You can manage your cookie preferences using the cookie banner shown when you first visit our site. For more information, please see our Cookie Policy.
12. Children’s privacy
Our website and grant application process are intended for use by adults representing organisations. We do not knowingly collect personal information from children.
13. Changes to this policy
We may update this Privacy Policy from time to time. The “last updated” date at the top of this page shows when it was last revised. We encourage you to review this page periodically.
14. Contact us
If you have any questions about this Privacy Policy or how we handle your personal information, please contact us:
The Primrose Trust, 3 Benham Chase, Stockcross, Newbury, RG20 8LQ