Thank you for visiting www.thetolkientrust.org (the Site). This Notice set outs the basis on which we will use any personal data provided to us by you, or received by us from third parties.

We are The Tolkien Trust registered in the United Kingdom as a company limited by guarantee under number 08354834 and as a charity under number 1150801, whose registered offices are at Prama House 267 Banbury Road, Oxford, OX2 7HT. We are the data controller of personal data provided to us and are registered with the ICO under registration number Z175497X. If you have any questions in relation to this notice, or in relation to our handling of personal data, you can contact us using the information on our Contact Us page.

Summary

Full details are set out in the relevant sections of this Notice below, but in summary:

• we generally receive personal data relating to you directly from you. For example, we will receive that data if you contact us through the Site or otherwise, or if we have a working relationship with you;

• personal data may occasionally be provided to us by third parties with whom each of you and us have a relationship. For example, if we work with your employer then they might provide us with your details;

• we use personal data conduct our charitable activities, keep appropriate records and meet our legal obligations;

• we only provide your personal data to third parties for our the purposes of our activities or as permitted by law;

• you have certain rights, prescribed by law, in relation to the processing of your data, such as rights to request access, rectification or deletion of your personal data;

• the Site [does not use cookies] [apart from Google Analytics][uses cookies]; and

• you can contact us to enquire about any of the contents of this Notice.

1. Our use of personal data

1.1 In this section we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing. When we refer to a “legal basis”, we mean a lawful basis set out in Article 6 of the General Data Protection Regulation as transposed into UK law (GDPR) under which we conduct the relevant processing.

Personal data we obtain from you

Usage data

1.2 We may process data about your use of the Site (usage data). This may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. This data is obtained through Google Analytics and will be aggregated and anonymised in such a way that it contains no information pertaining to any identifiable individual at all – as such it is not actually personal data but we address it in this Notice for completeness’s sake. We process usage data for the purpose of improving our Site.

Correspondence data

1.3 We may process personal data contained in or relating to any communication that you send to us, whether through the Site, by email, by post or otherwise. All of this together is correspondence data. This may include the communication content and metadata associated with the communication, as well as any contact details you provide to us such as your name, email address, phone number, job title, address or social media username. We process correspondence data for the purposes of communicating with you and record-keeping.

Transaction data

1.4 If we do business with you or your employer (whether as a grantee, commercial partner or otherwise), we may process information relating to transactions, such as bank account details, contact details or transaction data in relation to our business relationship or payments made by us to you or by you to us (business data). This may include your contact details, any bank account or sort code information provided for the purposes of making payment, transaction details (such as POs or invoices) and the contents of related correspondence and documents. The business data may be processed for the purpose of grantmaking, conducting and managing our business relationships and keeping proper records of transactions into which we have entered.

Personal data we obtain from others

1.5 Your personal data may be provided to us by someone other than you: for example, by your employer, by an organisation with whom you and we are both dealing or by someone who wishes to refer you to us or vice versa. Normally this data will be correspondence data or transaction data as described above and will be processed by us for the purposes described above.

Our legal basis of processing

1.6 We will process personal data only on lawful bases. In particular, we will process personal data on the following lawful bases identified in Article 6 GDPR:

(a) for the performance of a contract with you, or to take steps at your request prior to entering into a contract with you (Article 6(1)(b) GDPR);

(b) for our legitimate interests (Article 6(1)(f) GDPR). This may be our basis for processing:

• correspondence and transaction data (as we have an interest in properly administering our charitable activities, business interests, communications and transactions); and

• any personal data identified in this Notice where necessary in connection with legal claims (as we have an interest in the protection and assertion of our legal rights and those of others).

1.7 We may also process your personal data set out above where necessary for compliance with law (Article 6(c) GDPR).

2. Providing your personal data to others

2.1 We may disclose your personal data to our insurers, auditors, grant administrators and/or professional advisers as necessary for the purposes of obtaining professional advice and managing legal disputes.

2.2 We may disclose personal data to our suppliers in connection with the uses described above. For example, we may disclose:

(a) any personal data in our possession to suppliers which host the servers on which our data is stored;

(b) transaction information and billing contact details to our accountants; and

(c) transaction information and other relevant personal data to third parties for the purposes of fraud protection, credit risk reduction and debt recovery.

2.3 We do not allow our third-party service providers to use your personal data for their own purposes. They process your personal data for specified purposes and in accordance with our instructions and applicable law.

2.4 We may also disclose your personal data where necessary for compliance with law.

3. International transfers of your personal data

Some of the third parties to whom we may transfer your personal data, discussed above, may be located outside the UK and EEA or may transfer your personal data to their own service providers located outside the UK and EEA. If so, then we will ensure that transfers will only be made to countries in respect of which the European Commission has made an "adequacy decision”, or otherwise will only be made with appropriate safeguards, such as the use of standard data protection clauses adopted or approved by the UK ICO.

4. Retaining and deleting personal data

5.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.2 We may retain your personal data where necessary for compliance with a legal obligation to which we are subject, or in order to protect your or another individual’s vital interests.

6. Amendments

We may update this Notice from time to time by publishing a new version on the Site. You should check occasionally to ensure you are happy with any changes to this Notice, although we will notify you of material changes to this Notice using the contact details you have given us.

7. Your rights

7.1 We have summarized below the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. You can read guidance from the Information Commissioner’s Office at www.ico.gov.uk for a fuller explanation of your rights.

7.2 Some of your principal rights under data protection law are:

• the right to access: you have the right to confirmation as to whether or not we process your personal data and, where we do, to access to the personal data, together with additional information including details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data;

• the right to rectification: you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed;

• the right to erasure: in some circumstances you have the right to the erasure of your personal data. These might include if the personal data are no longer needed for the purposes for which they were processed. There are some exclusions from this right, such as where processing is necessary for compliance with a legal obligation or in connection with legal claims;

• the right to object to processing: you have the right to object to our processing of your personal data on the basis of the legitimate interests pursued by us or by a third party; and

• the right to complain to a supervisory authority: if you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the ICO.

• the right to complain to us: if you have any complaint about the manner in which we handle your personal data, please contact us using the details on the Contact Us page of our website. We will confirm receipt of your complaint within 30 days and will investigate promptly.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

8.4 Our Site does not use cookies, with the exception of Google Analytics. We use Google Analytics to analyse the use of the Site. Google Analytics gathers information about website use by means of cookies. The information gathered relating to the Site is used to create reports about the use of the Site. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

8.5 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via the support pages made available by your browser operator.

10. Third Parties and Security

10.1 The Site may contains links to third party websites and refers to third party service providers and other entities. If you follow a link to any third party website or deal with any third party entity referred to on the Site, then you should note that these third parties may have their own privacy and cookie policies, and that we are not responsible for their use of any personal data which you may provide to them. You should ensure that you have read and understood any relevant policies.

10.2 Although we do our best to ensure the security of personal data provided to us (and to use only reputable service providers), any transmission of data via the Internet is by its nature insecure and we cannot guarantee the security of any personal data you provide to us.

Last updated: 20 June 2026