1. PURPOSE OF THIS PRIVACY NOTICE
BuddyHub C.I.C. respects your privacy and is committed to protecting your personal data. This privacy notice aims to give you information on how BuddyHub C.I.C. treats and processes any personal data we collect from you or that you provide to us.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
By signing your Senior/Buddy Agreement you agree to the collection, storage and processing of your personal information in accordance with this policy.
BuddyHub C.I.C., company number 09332306 (“BuddyHub”) is registered under the Act as a Data Controller under number ZA119405.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Full name of legal entity: BuddyHub C.I.C.
Name and title of DPO: Catherine McClen – Founder/CEO
Email address: email@example.com
Postal address: 18-20 London Lane, London, E83PR
Telephone number: 0203 642 6871
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 24 May 2018 and historic versions can be obtained by contacting us.
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.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
How your personal data is collected
We use different methods to collect data from and about you. We may collect, use, store and transfer different kinds of personal data about you through:
Direct interactions – this includes data collected when you sign up to our newsletter, make a donation, purchase a product or service, take part in a competition, use our website, any data you may provide through our website including filling in a profile on our website or on paper or when you correspond with us by phone, e-mail or otherwise.
Automated technologies or interactions – as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
Third parties or publicly available sources – we may receive personal data about you from various third parties including analytics providers, advertising networks and search information providers, contact, financial and transaction data (from providers of technical, payment and delivery services), identity and contact data from data brokers or aggregators or from publicly available sources.
The information you give us may include:
Your name, address, date of birth, your ethnicity, your religious beliefs, your sexual orientation, marital status, title, date of birth, gender, e-mail address and phone number, financial and credit card information, details about payments to and from you and other details of products and services you have purchased from us, donations, purchases or orders made by you, photograph, your employment status, criminal records and convictions information about you (including alleged offences, for example safeguarding issues information), information about the accessibility of your home, your emergency contact, information about your values, skills, interests and aspirations, feedback, responses and information about your mental and physical health.
Information we collect may include:
Internet protocol (IP) address used to connect your computer to the Internet, your login information, information about your visit, products you viewed or searched for, page interaction information (such as scrolling, clicks, and mouse-overs), and any phone number used to call us, 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 our website, information about how you use our website, products and services, marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.
Information we receive from other sources may include:
Personal information about you from other sources such as if a family member, referrer or friend contacts us on your behalf.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Where we are relying upon your consent to process personal data, you can withdraw this at any time by contacting us at the number, email address or postal address given above.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
The following are the lawful grounds or bases for our use of your personal data:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- where it is in our legitimate interests to do so;
- to comply with our legal obligations;
- for a public task (a task in the public interest)
3.1 Information you give us:
A.to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
B.to deal with enquiries, complaints and feedback from you and people with whom you have interacted as part of your involvement with BuddyHub;
C.to provide third parties with anonymised information about you;
D.to show the impact of our work to funders/stakeholders
F.to send you emails; and
G.to notify you about changes to our service.
3.2 Information we collect about you:
A.to administer our site and services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
B.to improve our site and services to ensure that content is presented in the most effective manner for you and for your computer;
C.to allow you to participate in interactive features of our service, when you choose to do so;
D.as part of our efforts to keep our site and service safe and secure;
E.to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
F.to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
3.3 Information we receive from other services:
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
This personal data, whether it is held on paper, digitally or via other media, will be subject to the appropriate legal safeguards as specified in the General Data Protection Regulation 2016 (GDPR).
Contact us to find out more about the types of lawful basis that we will rely on to process your personal data or if you need details about the specific legal ground we are relying on to process your personal data. 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.
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. You have the right to withdraw consent to marketing at any time by contacting us.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us
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, made a donation, given prior consent to third parties 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.
Third party marketing
We will get your express opt-in consent before we share your personal data with any company outside the BuddyHub C.I.C. group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time at firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
5. DISCLOSURES OF YOUR PERSONAL DATA
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.
We may share information with the following external or “third party” organisations for the purposes listed below:
A. to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
B. to comply with any laws, regulations or requirements mandated by Government;
C. to business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you
D. if we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- if BuddyHub C.I.C. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
F. risk of serious harm or abuse to you or someone else or if it is necessary to disclose information about you or your health to ensure your safety, or those of others, while you use BuddyHub’s services. In this instance we may have to pass information onto a third party to the extent necessary, including but not limited to, the emergency services, your designated emergency contact or a BuddyHub employee or volunteer.
6. INTERNATIONAL TRANSFERS
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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, 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 (including the ICO) of a breach where we are legally required to do so.
8. 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 can be requested from us by contacting us.
9. YOUR LEGAL RIGHTS
Under certain circumstances you have these rights under data protection laws in relation to your personal data:
- The right to be informed about the processing of your personal data
- The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed
- The right to object to processing of your personal data
- The right to restrict processing of your personal data
- The right to have your personal data erased (the “right to be forgotten”)
- The right to request access to your personal data and to obtain information about how we process it
- The right to move, copy or transfer your personal data (“data portability”)
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
If you wish to exercise any of the rights set out above, please contact us. 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.
10. WITHDRAWING CONSENT
You can withdraw your consent to us using your personal information at any time. Please contact us by email at or by phone if you want to withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services.
11. WHAT WE MAY NEED FROM YOU
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.
12. TIME LIMIT TO RESPOND
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.