1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

  1. Credit

2.1    This document was created using a template from SEQ Legal (http://www.seqlegal.com).

  1. How we use your personal data

3.1    In this Section 3 we have set out:

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

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

(c)    the legal bases of the processing.

3.2    We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.3    We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, address, telephone number, email address, gender, date of birth, employment details, DBS status and Right of Residence. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.4    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.5    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.6    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.7    We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.8    In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

4.3    We may disclose your personal data to our website provider insofar as reasonably necessary to enable us and them to carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

(a) Your data will be made available to our website provider
(b) The data that may be available to them include any of the data we collect as described in section 3 above
(c) Our website provider will not transfer your data to any third party, or transfer your data outside of the EEA.
(d) They will store your data for a maximum of 7 years.
(e) This processing does not affect your rights under Section 7 of this privacy policy.

4.4    Financial transactions relating to our website and services are handled by our payment services providers, Stripe and GoCardless. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/gb/privacy and https://gocardless.com/legal/privacy/.

4.5    In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Retaining and deleting personal data

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    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.

5.3    Without prejudice to Section 5.2, we will usually retain your personal data for a period of ten years, at the end of which period it will be deleted from our systems.

5.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of your service data will be determined based on the date of your most recent communication with us.

(b) the period of retention of your communication data will be determined based on the date of your most recent communication with us.

5.5    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

  1. Your rights

7.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a fee (currently fixed at GBP 10); and

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

7.2    We may withhold personal information that you request to the extent permitted by law.

7.3    You may instruct us at any time not to process your personal information for marketing purposes.

7.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

  1. 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.

  1. Cookies that we use

9.1    We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website (the cookie used for this purpose is: ASP.NET_SessionId);

(b)    status - we use cookies to help us to determine if you are logged into our website (the cookie used for this purpose is: MemberLoggedIn);

(e)    advertising - we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: IDE, DSID, _ct_rmm);

(f)    analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: _unam, ai_session, ai_user); and

(g)    cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (the cookie used for this purpose is: cc_cookie_accept).

  1. Cookies used by our service providers

10.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.[ The relevant cookies are: _utma, _utmz, _ga, _gid, _gat_UA-XXXXXXXX-X (where the Xs are replaced by the Google Analytics ID number).