Privacy and cookies policy
1. IMPORTANT INFORMATION AND WHO WE ARE
We collect, use and are responsible for certain personal data about you. When we do so we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that personal data for the purposes of those laws.
1.1 YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.2 THIRD-PARTY LINKS
1.3 KEY TERMS
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means freely given, specific, informed and unambiguous indication of a data subject's wishes which is indicated by a positive action.
External Third Parties means:
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances.
- Other third we may contract with, which may include, but is not limited to, marketing communications and market research agencies, fraud prevention agencies.
Legitimate Interest means the interest of our organisation in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. We, us, our means London LGBT Community Pride CIC, a community interest company (registered number 08321669) and having its registered office at Cannon Place, 78 Cannon Street, London, EC4N 6AF.
1.4 THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where it is no longer possible to identity the person (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, relationship/ marital status, title, date of birth and gender identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and/or our app.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and/or our app, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Sensitive Personal Data includes information about your racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, data concerning health, sex life or sexual orientation.
1.5 HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms on our website and/or our app or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase products from our website or tickets for our events;
- apply to volunteer;
- donate to us;
- subscribe to our mailing list;
- complete any other forms on our website (such as “report an issue” forms);
- enter a competition (such as Pride’s Got Talent) or any promotion;
- give us some feedback; or
- participate in our surveys or research studies
- Third parties. We may receive personal data about you from various third parties as set out below:
- Identity Data from the following parties:
- event organisers for third party events;
- Technical Data from the following parties:
- analytics providers such as Google Analytics (based outside the EU).
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation. Where you have given us specific and informed consent.
See section 1.3 of this policy above find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message or in relation to your participation in our surveys and/or research studies. You have the right to withdraw consent to marketing, and your participation of surveys or research at any time by contacting us, for our contact details, see below.
3. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|PURPOSE/ACTIVITY||TYPE OF DATA||LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST|
To enable you to:
To allow you to sign up for our mailing list, or, remove you where you no longer wish to receive our updates
To manage our relationship with you which will include:
any other activity relating to the management of our relationship with you.
To administer and protect our organisation and this website and/or our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To deliver relevant website and/or app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how users of our website and/or our app use our services and to inform our marketing strategy)
To use data analytics to improve our website and/or our app, events, products and services and marketing
Necessary for our legitimate interests (to develop our products/services and grow our organisation)
To enable you to take part in our surveys and research and to allow us to report on the outcome of our research.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you change your mind and no longer wish to receive such communications or wish to change your preferences, you can opt out at any time by contacting us using the details provided below.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
5. THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.
6. OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
7. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 3 above.
- External Third Parties as set out in section 1.3 of this policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data, for more information see section 12 below. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website and/or our app. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website and/or our app when they are using it. This helps us to improve the way our website and/or our app works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website and/or our app. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website and/or our app, the pages you have visited and the links you have followed. We will use this information to make our website and/or our app and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Facebook tracking cookie
Social sharing, tracking, and advert targeting
Google advertising cookie used for user tracking and advert targeting purposes
Google advertising cookie used for user tracking and advert targeting purposes
Used by Google to store user preferences and information of Google Maps
Cookie for fraud prevention
12. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. In particular, you have the following rights which you can exercise free of charge, by contacting us via the details below:
Access - The right to be provided with a copy of your personal data (the right of access).
Rectification - The right to require us to correct any mistakes in your personal data.
To be forgotten - The right to require us to delete your personal data—in certain situations.
Restriction of processing - The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability - The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object - The right to object:
- at any time to your personal data being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. HOW TO CONTACT US
PO Box 71920, London NW2 9QN
firstname.lastname@example.orgMatthew Kent, Data Protection Officer London
LGBT Community Pride CIC
PO Box 71920, London NW2 9QN
This version was last updated on 24 May 2018 and historic versions can be obtained by contacting us at the details provided above.
15. HOW TO COMPLAIN
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at http://ico.org.uk/concerns or telephone: 0303 123 1113.