Our registered office is Ashleigh, Constitution Hill, Southwold, Suffolk IP18 6HE.
1. Purpose of the policy
1.1. This policy sets out how we will collect, process, store and use the information we hold about you.
1.2. We take seriously the protection of your privacy and confidentiality and we understand that you are entitled to know that your personal data will not be used for any unintended purpose and will not accidentally fall into the hands of a third party.
1.3. We undertake to preserve the confidentiality of all information you provide to us.
1.4. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
1.5. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. This information can be found at www.knowyourprivacyrights.org
1.6. Except as set out below, we do not share, or sell, or disclose to a third party, any information personal information we collect.
2. The basis on which we process information about you
2.1. The law requires us to determine the defined bases under which we process different categories of your personal information, and to notify you of the basis for each category.
2.2. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
2.3. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
3. Information we process because we have a contractual relationship with you
3.1. When you use our share owners membership portal or buy a service or product from us, a contract is formed between you and us.
3.2. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
3.3. We may use it in order to:
3.3.1. verify your identity for security purposes
3.3.2. provide you with our services
3.3.3. provide you with suggestions and advice on products, services and how to obtain the most from using our website
3.4. We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
3.5. Additionally, we may aggregate this information in a general way and use it to provide class information, for example, to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
3.6. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
4. Information we process with your consent
4.1. Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website, sign up for our newsletter, or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
4.3. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
4.4. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
4.5. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. This may include partners on our programmes.
4.6. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
4.7. You may withdraw your consent at any time by instructing us firstname.lastname@example.org. However, if you do so, we may not be able to provide you with our services further.
5. Information we process because we have a legal obligation
5.1. We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
5.2. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
5.3. This may include your personal information.
6. Complaints regarding content on our website
6.1.If you complain about any of the content on our website, we shall investigate your complaint.
6.2. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
7. Information relating to your method of payment
7.1. Payment information (e.g. credit or debit card information) is never taken by us or transferred to us through our website. Our employees and contractors never have access to it.
7.2. At the point of payment, you are transferred to a secure page on the website of our payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
8. Job application and employment
8.1. If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
8.2. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
10. Sending a message to our support team
10.1. When you contact us, whether by telephone, through our website or by e-mail, we may collect the data you have given to us in order to reply with the information you need.
10.2 We keep personally identifiable information associated with your message, such as your name and email address so as to be able to provide a high quality service.
11.1. When we receive a complaint, we record all the information you have given to us.
11.2. We use that information to resolve your complaint.
11.3. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
11.4. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
12. Access to your own information
12.1. Access to your personal information
12.1.1. You may obtain a copy of any information we hold about you by sending us a request at email@example.com.
12.1.2. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
12.2. Removal of your information
12.2.1. If you wish us to remove personally identifiable information from our systems, you may contact us at firstname.lastname@example.org.
12.2.2. This may limit the service we can provide to you.
12.3. Verification of your information
12.3.1. When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
13. Encryption of data sent between us
13.1. We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
13.2. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
14. How you can complain
14.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
14.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at ico.org.uk/concerns
15. Retention period for personal data
15.1. Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
15.1.1. to provide you with the services you have requested. This includes a record of your transactions with us in order to provide the best possible service should you contact us in the future;
15.1.2. to comply with other law, including for the period demanded by our tax authorities;
15.1.3. to comply with our funding agreements which usually expect us to keep records for up to seven years;
15.1.4. to support a claim or defence in court.
16.1. We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.