1. IMPORTANT INFORMATION AND WHO WE ARE
Full name of legal entity:
ChangeXtra Limited, Company Number: 13393825
Email address: firstname.lastname@example.org
Postal address: Ingenuity Lab, Ingenuity Centre, Triumph Road, Nottingham, NG7 2TU
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however,appreciate the chance to deal with your concerns before you approach the ICO soplease contact us in the first instance.
2. THEDATA 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).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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have theright to withdraw consent to marketing at any time by contacting us.
We may collect, use, store and transfer different kinds of personal data about you as follows:·
When you contact us
Meeting Call with us: we may collect your first name, last name, email address, telephone number or any other relevant information you disclose to us when you contact us. We will use this information to discuss your enquiry. The purpose for processing this information is to deal with and respond to your message. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (in order to communicate with you).
Emailing us: we may collect your first name, last name, email address, telephone number or any other relevant information you disclose to use when you contact us. We will use this information to respond to your message. Emails are monitored for malicious content and we take every reasonable precaution to ensure that any attachment sent by us is virus free. However, we cannot accept liability for any damage sustained as a result of software viruses and would advise that you carry out your own virus checks before opening any attachment from us. The purpose for processing this information is to deal with and respond to your message. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (in order to communicate with you).
Sign up for our free e-book, mailing list or electronic newsletter: when you sign up for any of the above you may give us your first name, last name, emailaddress, telephone number, addressand any other personal information you include in the sign up form. We will usethis information to send you our electronic newsletter.Thepurpose for processing this information is to send you our newsletter. Thelawful basis we rely on to process your personal data is that it is necessaryfor the purposes of our legitimate interests (in order to communicate with you).
The purpose for processing this information is to communicate with you and respond to any messages. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (in order to communicate with you).·
When you book an appointment or meeting
We will collect your first name, last name, email address, address and payment details to process your order. Your payment details will be shared with our third party payment provider. We will use this information to book your appointment and provide you with a confirmation email setting out the date and time of your appointment. The purpose for processing this information is to process your order, including managing payments, fees and charges and collecting and recovering money owed to us. The lawful basis we rely on to process your personal data is that it is necessary for the performance of a contract with you and that it is necessary for our legitimate interests (to recover debt due to us). At this point, we will also collect some background information, including Special Category Personal Data (see further detail below). The purpose for processing the background information is to help inform your appointment and make it personal and useful to you. We will not use your Special Category Data unless you have provided express consent to do so. Where we process such Special Category Personal Data, we will ensure we are permitted to do so under data protection laws. ·
During your appointment or meeting:
We will also collect further information from you during your appointment, including Special Category Data (see further detail below). The purpose for processing this information is to keep a record of communications between us and to provide you with the services you have requested and signpost you to relevant resources. We will not use your Special Category Data unless you have provided express consent to do so. Where we process such Special Category Personal Data, we will ensure we are permitted to do so under data protection laws.
Our website analytics:
We may collect non-personal information about you when you use our website. This information may include the browser name, the type of computer and technical information about your means of connecting to our site, such as the operating system and the internet service providers used. We may share this information with Google (California), as Google Analytics will track the data as per the above statement. The purpose for processing this information is to use data analytics to improve our website, services, marketing, relationships and experiences. The lawful basis we rely on is that it is necessary for our legitimate interests (to define types of applicants for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Security and performance:
We may collect first name, last name, date of birth, gender, address, email address and telephone numbers internet protocol (IP)address, 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 to enable us to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).The purpose for processing this information is security and safety reasons. The lawful basis we rely on to process your personal data is that it is necessary for the purposes of our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and because it is necessary to comply with a legal obligation.·
If you consent to receiving our marking communications, we may collect first name, last name, postal address, email address, telephone numbers, 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 use this information to make suggestions and recommendations to you about goods or services that may be of interest to you. The purpose for processing this information to make suggestions and recommendations to you about goods or services that may be of interest to you. The lawful basis we rely on is that it is necessary for our legitimate interests (to study how you use our services, to develop them, to grow ChangeXtra and to inform our marketing strategy).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us and 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 third party for marketing purposes. Opting out: You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at email@example.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a loan, grant or scholarship application or a loan, grant or scholarship offer or award.
Special Categories of Personal Data
The details about your race or ethnicity, religious or philosophical beliefs, sex or sexual orientation or health that we may collect during your appointment amounts to Special Category Personal Data, to which additional protections apply under data protection law. We will not use your Special Category Data unless you have provided express consent to do so. Where we process such Special Category Personal Data, we will ensure we are permitted to do so under data protection laws. We do not collect any information about criminal convictions and offences.
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. In this case, we may have to cancel an application you have with us but we will notify you if this is the case at the time.
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
.3. DISCLOSURESOF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out above in relation to the relevant activity. ·
External Third Parties
Mentors, with whom you have booked an appointment with.
Payment partners acting as processors who provide payment services.
Service providers acting as processors based in the UK who provide IT and system administration services.·
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.
4. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the UK) unless otherwise set out in this policy. Some of our external third parties maybe based outside the UK so their processing of your personal data will involve a transfer of data outside the UK, namely Google (California). Please contact us if you want further information on the specific mechanism used by us when your personal data is transferred out of the UK.
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, trustees, 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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal data are available on request.
7. YOURLEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: ·
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.·
Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.·
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. ·
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.·
Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: ·
If you want us to establish the data's accuracy.·
Where our use of the data is unlawful but you do not want us to erase it.·
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.·
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. ·
Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Widraw consent at any timewhere we are relying on consent to process your personal data. However, thiswill not affect the lawfulness of any processing carried out before youwithdraw your consent. If you withdraw your consent, we may not be able toprovide certain services to you. We will advise you if this is the case at thetime you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us. No fee usually required. 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 could refuse to comply with your request in these circumstances.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Legitimate Interest means the interest of ChangeXtra in conducting and managing the company 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.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.