1.Important information and who we are 2.The data we collect about you 3.How is your personal data collected? 4.How we use your personal data 5.Disclosures of your personal data 6.International transfers 7.Data security 8.Data retention 9.Your legal rights 10.Glossary
The Home Office is a trading name of The HO Tring Ltd (Co. No. 11207935). The Home Office provides a club for Members to work, network and grow in a shared work space. Members can do all this at Pennyroyal Court, Station Road, Tring, HP23 5QY.
• You use our website (regardless of where you visit it from) or; • Enquire about Home Office membership or; • Apply for Home Office membership or; • You use your members account via our online (intranet) platform or; • We administer membership for members and any persons associated with members e.g. employees of corporate members.
and tells you about your privacy rights and how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE
Our website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: The HO Tring Ltd.
Email address: email@example.com
Postal address: Pennyroyal Court, Station Road, Tring, Hertfordshire HP24 5QY.
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.
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.
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about membership payments you have made to The Home Office 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 our website.
- 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, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not need to nor will we collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health (other than for Health & Safety records keeping purposes, in the case of your being involved in an accident and/or requiring medical treatment on our premises), and genetic and biometric data). Nor do we 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 (for example, to provide you with The Home Office membership any other associated services). In this case, we may have to decline your membership application or cancel your membership (or association with any membership) and/or terminate your access to our services, but we will notify you if this is the case at the time.
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 Identity, Contact and Financial Data by filling in forms (either online or by post) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 1. apply for The Home Office membership or any other of our products or services; 2. create and use membership account on our online (intranet) members platform; 3. subscribe to any of our services or publications; 4. request marketing to be sent to you; 5. enter a competition, promotion or survey; or 6. give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will 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. Please see information about cookies below for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 1. Technical Data from the following parties: a. analytics providers such as Google based inside OR outside the UK/EU; b. advertising networks based inside or outside the EU; and c. search information providers such as Google based inside OR outside the UK/EU. 2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services. 3. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
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 obligation.
See the Glossary below to 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 although we will get your consent before 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, 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 list below:
To process your application for The Home Office membership or register you as a new member and (if the case) any persons associated with your membership (including carrying out identity checks) Type of data: (a) Identity (b) Contact Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to verify your identity)
To deliver our membership and other services including: (a) Manage your membership payments fees and charges (b) Collect and recover money owed to us Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to ensure your membership and/or use of your online account is not being used fraudulently or for unlawful purposes and to report any apparent irregularities to the issuing bank) (c) Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how members use our products/services, to develop them and grow our business)
To administer and protect our business, our website and (online) members account services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Type of data: (a) Identity (b) Contact (c) Technical Lawful basis for processing including basis of legitimate interest: (a) Necessary for 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) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Type of data: (a) Technical (b) Usage Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of prospective members for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
When you sign up for The Home Office membership we may ask if you'd like to be contacted about new The Home Office products, services, offers and tips about your membership. If you tell us you're happy to be contacted, we'll send you information about things you might be interested in via email, SMS or push notifications.
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 services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into your member account and checking or 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.
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, , or other membership services or transactions.
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. This enables the web server to identify and track the web browser.
We may obtain some information about your general internet usage by using a cookie. They help us to improve our website and our member account services, and to deliver a better and more personalised service.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. However, if you block all cookies, this may have a negative impact upon the use and experience of our website and services.
We may collect information your IP address. This is statistical does not identify any individual.
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
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.
The service providers for our payment systems and for our marketing communications systems are based in the US, so their processing of your personal data will involve a transfer of data outside the EEA; see External Third Parties as set out in the Glossary
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. b. 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. c. 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. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 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.
By law we have to keep basic information about our members (including Contact, Identity, Financial and Transaction Data) for six years after they cease being members for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights in the Glossary below below for further information.
In some circumstances we will 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see your legal rights in the Glossary below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact our compliance team via the means set out in Contact Details above.
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 our business in conducting and managing our business to enable us to give you the best service/product 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.
INTERNAL THIRD PARTIES
Our parent company, Future Proof Enterprises Limited, acting as data processor, which is based in England and provide IT, system administration services as well as Legal, Compliance and Finance departmental support.
EXTERNAL THIRD PARTIES
- Nexudus Limited whose address is 1 College Yard, 56 Winchester Avenue, London, England, NW6 7UA (ICO registration number ZA271322), the IT provider of our online member account services.
- Stripe, Inc, 510 Townsend Street, San Francisco, California 94103, USA (an EU-US/Swiss-EU Privacy Shield framework participant), the provider of our payment technology and services.
- The Rocket Science Group LLC (trading as ‘MailChimp’) whose address is 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, Georgia 30308, USA (an EU-US/Swiss-EU Privacy Shield framework participant), the provider of our marketing communications tools.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
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 the 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. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
© 2019, The HO Tring Ltd trading as The Home Office.