Isle of Man Imagination Library is a charity registered in the Isle of Man (Charity No. 1364). We are registered with the Isle of Man Information Commissioner as a Data Controller and a Data Processor (R004293).

The Dollywood Foundation Inc. (DWF) is the data controller for Dolly Parton’s Imagination Library (DPIL), responsible for the secure capture, storage, use and disposal of all Personally Identifiable Information (PII) captured in association with the book gifting programme, for example, child and legal guardian details.  This data is shared with Isle of Man Imagination Library (IOMIL) via DWF’s Affiliate Data Sharing Policy.  We are affiliate #1004 of the DPIL.

The IOMIL is the data controller for any PII captured in association with fundraising for, and promotion of, the programme’s delivery on the Isle of Man, for example, the names of donors, sponsors and local champions.

Postal address

Isle of Man Imagination Library
2 Mill Cottages
Mill Road
Ballasalla
IM9 2EG

Email

data@imaginationlibrary.im

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details

• Addresses

• Date of birth

• Payment details (including card or bank information for transfers and direct debits)

• Account information

• Website user information (including user journeys and cookie tracking)

• Records of meetings and decisions

• Information relating to compliments or complaints

• Information relating to sponsorship

Our lawful base for collecting or using personal information to provide services and goods is consent.

For the purpose of book gifting

Personal information is collected from subjects and their legal guardians directly.

For the purpose of book gifting, PII will only be collected from the legal guardian by

• direct input into the Book Order System (BOS) online at DWF’s site imaginationlibrary.com

• direct input into BOS accessed via the embedded form on the IOMIL’s site imaginationlibrary.im

• completing a paper registration form which will be input into BOS by an approved user and the paper form destroyed within 30 days.

For the purpose of fundraising and promotion

Personal information is collected from subjects directly.

PII may be collected via electronic means (e.g. incoming emails) or input into an electronic system by the IOMIL for record-keeping purposes.

For the purpose of book gifting

The full registration record is maintained in the Book Order System (BOS) for programme administration, research and programme reporting from the date of registration up to the month of child’s 11th birthday. Upon month of child’s 11th birthday, DWF anonymises the registration record, permanently deleting all personally identifiable information (PII), and retains the anonymised record in the BOS for program reporting until the DWF ceases operation.

The IOMIL will have access to the full registration record up to the month of child’s 5th birthday.  Upon month of child’s 5th birthday, IOMIL will only be able to access an amended record, with the child’s name and account email removed, for 12 months. Upon the month of child’s 6th birthday, the registration record will no longer available to IOMIL in BOS.

It is necessary for the IOMIL to download reports monthly from BOS for record-keeping purposes, these will be stored in compliance with DWF’s requirements and permanently deleted within 12 months.

Any data deletion requests will be processed by the DWF and they will inform IOMIL, who will delete any PII from downloaded reports.

For the purpose of fundraising and promotion

The IOMIL will permanently delete data or anonymise operational data after 6 years.

Data processors

The Dollywood Foundation 

DWF is a processor as well as a controller. DWF manages the Book Ordering System (BOS) which contains the details of registered children and their legal guardians.

Microsoft

IOMIL utilises Microsoft Office 365 (M365) for operation purposes.  IOMIL has control over what we use M365 for, as well as its implementation and configuration for our purposes.  Data is held in the UK.

Mailchimp

The Book Ordering System (BOS) integrates with Mailchimp for the purpose of sending bulk emails to legal guardians.

SumUp

SumUp is used as a payment provider for IOMIL.

Cloudflare

The IOMIL website (imaginationlibrary.im) utilises Cloudflare as a proxy for caching and DDOS protection.

Google Sites

The IOMIL website (imaginationlibrary.im) is hosted on Google Sites.

Selected partners

Research and Educational Advancement Partners

To measure the benefits of the programme, datasets may be created and shared with research and educational advancement partners who have been explicitly approved and who have entered into a ‘Research and Data Sharing Agreement’ with DWF.

No first party cookies are set.

Cloudflare

Cloudflare which is used for caching and DDOS protection, sets uses some strictly necessary cookies. You can read Cloudflare's privacy policy and Cloudflare's cookie policy. Website analytics are limited to Cloudflare web analytics. 

Google Sites

The site is hosted with Google Sites. Which sets some essential cookies as part of its hosting, it may also set marketing cookies but it should not do that unless you consent via the popup, however, the popup does not seem to appear consistently. These cookies are used throughout Google services, but you can opt-out.  Please refer to Google’s privacy & terms and read how Google uses cookies.  Google analytics is not used on this site.

The DWF is an international organisation and some of our processors are also international organisations which will transfer personal information outside of the Isle of Man / UK. However, all organisations will comply with UK GDPR or equivalent, making sure appropriate safeguards are in place. Please refer to the DWF’s privacy policy for the Imagination Library.

Under data protection law, you have rights including:

Your right of access 

You have the right to ask us for copies of your personal data.

Your right to rectification

You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure

You have the right to ask us to erase your personal data in certain circumstances.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing

You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability

You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

Your right to withdraw consent

When we use consent as our lawful basis you have the right to withdraw your consent.

You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice

Complain to us

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

Complain to the ICO

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO's address: 

Information Commissioner’s Office
First Floor, Prospect House,
Prospect Hill,
Douglas,
IM1 1ET
Telephone: 01624 693260

https://www.inforights.im/complaint-handling/how-to-make-a-complaint-to-the-information-commissioner/

19th June 2024