Privacy Policy
1. Introduction
1.1 This
policy applies where we are acting as a data controller with respect to the
personal data of such persons; in other words, where we determine the purposes
and means of the processing of that personal data.
2. Credit
2.1 This document was created using a template from Docular
(https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In
this Section 3 we have set out the general categories of personal data that we
process[ and, in the case of personal data that we did not obtain directly from
you, information about the source and specific categories of that data].
3.2 We
may process data enabling us to get in touch with you ("contact data").
The contact data may include your name, email address, telephone number, postal
address and/or social media account identifiers. The source of the contact data
is you and/or your employer. If you log into our website using a social media
account, we will obtain elements of the contact data from the relevant social
media account provider.
3.3 We
may process your website user account data ("account data"). The
account data may include your account identifier, name, email address, business
name, account creation and modification dates, website settings and marketing
preferences. The primary source of the account data is you and/or your
employer, although some elements of the account data may be generated by our
website. If you log into our website using a social media account, we will
obtain elements of the account data from the relevant social media account
provider.
3.4 We
may process information contained in or relating to any communication that you
send to us or that we send to you ("communication data"). The
communication 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.
3.5 We
may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical
location, browser type and version, operating system, referral source, length
of visit, page views and website navigation paths, as well as information about
the timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking system.
4. Purposes of processing and legal bases
4.1 In
this Section 4, we have set out the purposes for which we may process personal
data and the legal bases of the processing.
4.2 Operations
- We may process your personal data for the purposes of operating our
website. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website, services and ministry.
4.3 Relationships
and communications - We may process contact data, account data, transaction
data and/or communication data for the purposes of managing our relationships,
communicating with you (excluding communicating for the purposes of direct
marketing) by email, SMS, post, fax and/or telephone, providing support
services and complaint handling. The legal basis for this processing is our
legitimate interests, namely communications with our website visitors, service
users, maintenance of relationships, and the proper administration of our
website, services and ministry.
4.4 Record
keeping - We may process your personal data for [the purposes of creating
and maintaining our databases, back-up copies of our databases and our business
records generally. The legal basis for this processing is our legitimate
interests, namely ensuring that we have access to all the information we need
to properly and efficiently run our ministry in accordance with this policy.
4.5 Legal
claims - We may process your personal data 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.
4.6 Legal
compliance and vital interests - We may also process 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.
5. Providing your personal data to others
5.1 Your
personal data held in our website database will be stored on the servers of our
hosting services providers.
5.2 In
addition to the specific disclosures of personal data set out in this Section
5, we may 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.
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise, or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal
data
6.1 You
acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This
Section 7 sets out our data retention policies and procedures, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
7.2 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.
7.3 We
will retain your personal data as follows:
(a) contact
data will be retained for a minimum period of 3 years following the date of the
most recent contact between you and us, and for a maximum period of 3 years following
that date];
(b) account
data will be retained for a minimum period of 1 year following the date of
closure of the relevant account, and for a maximum period of 1 year following
that date;
(c) [transaction
data will be retained for a minimum period of 3 years following the date of the
transaction, and for a maximum period of 3 years following that date];
(d) communication
data will be retained for a minimum period of 3 years following the date of the
communication in question, and for a maximum period of 3 years following that
date];
(e) usage
data will be retained for 3 years following the date of collection; and
(f) will
be retained for a minimum period of 3 years and for a maximum period of 3 years.
7.4 Notwithstanding
the other provisions of this Section 7, 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.
8. Your rights
8.1 In
this Section 8, we have listed the rights that you have under data protection
law.
8.2 Your
principal rights under data protection law are:
(a) the
right to access - you can ask for copies of your personal data;
(b) the
right to rectification - you can ask us to rectify inaccurate personal data
and to complete incomplete personal data;
(c) the
right to erasure - you can ask us to erase your personal data;
(d) the
right to restrict processing - you can ask us to restrict the processing of
your personal data;
(e) the
right to object to processing - you can object to the processing of your
personal data;
(f) the
right to data portability - you can ask that we transfer your personal data
to another organisation or to you;
(g) the
right to complain to a supervisory authority - you can complain about our
processing of your personal data; and
(h) the
right to withdraw consent - to the extent that the legal basis of our
processing of your personal data is consent, you can withdraw that consent.
8.3 These
rights are subject to certain limitations and exceptions. You can learn more
about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en
and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].
8.4 You
may exercise any of your rights in relation to your personal data [by written
notice to us, using the contact details set out below].
9. About cookies
9.1 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.
9.2 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.
9.3 Cookies
may not contain any information that personally identifies a user, but personal
data that we store about you may be linked to the information stored in and
obtained from cookies.
10. Cookies that we use
10.1 We
use cookies for the following purposes:
(a) authentication
and status - we use cookies to identify you when you visit our website and
as you navigate our website, and to help us determine if you are logged into
our website;
(c) personalisation
- we use cookies to store information about your preferences and to personalise
our website for you;
(d) security
- we use cookies [as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally;
(f) analysis
- we use cookies to help us to analyse the use and performance of our website
and services; and
(g) cookie
consent - we use cookies to store your preferences in relation to the use
of cookies more generally.
11. Cookies used by our service providers
11.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.
11.2 We
use Google Analytics, which gathers information about the use of our website
and uses cookies for this purpose. We use the information gathered by Google
Analytics to create reports about the use of our website. You can find out more
about Google's use of information by visiting https://policies.google.com/technologies/partner-sites
and you can review Google's privacy policy at https://policies.google.com/privacy.
The cookies used by Google Analytics are named _ga and _ga+container-id.
12. Managing cookies
12.1 Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser and from version to version.
You can obtain up-to-date information about managing cookies via these links:
(a) https://support.google.com/chrome/answer/95647
(Chrome);
(b) https://support.mozilla.org/en-US/products/firefox/privacy-and-security
(Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/
(Opera);
(d) https://support.apple.com/en-gb/guide/safari/welcome/mac
(Safari); and
[additional list items]
12.2 Blocking
all cookies will have a negative impact upon the usability of many websites.
12.3 If
you block cookies, you will not be able to use all the features on our website.
13. Amendments
13.1 We
may update this policy from time to time by publishing a new version on our
website.
13.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.
14. Our details
14.1 This
website is owned and operated by Into The Light.
14.2 You can contact us using our website contact form
https://into-the-light.uk/page/contact-us.html