1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors; this policy explains how we will treat your personal information.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website, and we will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to the Solidarity Economy Association Ltd.
1.5 This document was created using a template from SEQ Legal (http://www.seqlegal.com/)
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process the following kinds of personal information:
1. Data about your use of our website (usage data) that may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. The source of the usage data is our analytics tracking system, Matomo.
2. information that you post for publication on our website (for example by commenting on our posts (“publication data”).
3. Information contained in any enquiry you submit to us regarding our work, services or activity (“enquiry data”).
4. information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”).
5. information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence 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.
6. We may process any other personal information that you choose to send us.
2.3 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of our website.
2.4 On the basis of legitimate interest to run our organisation, we may use your personal information to apply to A, B, I, J, K below:
Where you have given us consent, we may use your personal information to complete C, D, E, F, G, H below:
1. Administer our website and business
2. Personalise our website for you
3. Send you non-marketing communications
4. Send you email notifications that you have specifically requested
5. Send you our email newsletter, if you have requested it
6. Send you marketing communications relating to our organisation which we think may be of interest to you, either by post, email or similar online technology, depending on which you have specifically agreed to (you can inform us at any time if you no longer wish to receive marketing communication)
7. Provide third parties with statistical information about our users (but those third parties will not be able to identify and individual user from that information)
8. Deal with enquiries and complaints made by or about you relating to our website
9. Keep our website secure
10. Verify compliance with the terms and conditions governing the use of our website
11. To conduct aggregate analysis and to develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our organisation.
2.5 We may process any of your personal data identified in this policy 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.
2.6 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of 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.
2.8 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 In addition to the specific disclosures of personal data set out in this Section 4, 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.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
4.2 You acknowledge that personal data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 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.
5.3 Without prejudice to section 6.2, we will usually delete all inactive data after 10 years.
5.4 Notwithstanding the other provisions of this Section 5, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store all your personal data on secure servers, personal computers and mobile devices.
6.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email or by publishing a message on our website.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your rights in relation to your personal data by written notice to us.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9.3 We operate a number of social media pages (including Facebook, Twitter, You Tube and Instagram). Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated by emailing dataprotection@solidarityeconomy.coop
11. About cookies
11.1 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.
11.2 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.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11.4 We use cookies on our website.
11.5 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.6 We use Matamo to analyse the use of our website. Matomo gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
11.7 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 however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.8 Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
11.9 You can manage your preferences relating to the use of cookies on our website by visiting: [URL]
12. Our details
12.1 We are registered as a data controller with the UK Information Commissioner’s Office.
12.2 Our data protection registration number is ZA296337.
12.3 This website is owned and operated by the Solidarity Economy Association Ltd.
12.4 We are registered in England and Wales under registration number 10733713, and our registered office is at Makespace Oxford, 1 Aristotle Lane, Oxford, OX2 6TP.
12.5 Our principal place of business is at Makespace Oxford, 1 Aristotle Lane, Oxford, OX2 6TP.
12.6 You can contact us:
(a) by post, using the postal address given above;
(c) by telephone, on the contact number published on our website from time to time;
or
(d) by email, using the email address dataprotection@solidarityeconomy.coop