25th May 2018
2.Who We Are
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
· Name Daphne Richardson T/A Freshfield Fitness
· Our registered address is 12 Wrigleys Close, Formby L37 7DT
· Our Data Protection Executive is Daphne Richardson and she can be contacted at email@example.com
· Our Webpage is www.freshfieldfitness.co.uk
3.What we may collect
We may collect and process the following data about you:
· Information you put into forms or surveys on our site at any time
· A record of any correspondence between us
· Details of transactions you carry out through our site
· Details of your visits to our site and the resources you use including traffic data, location data, weblogs and other communication data
· Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our bank processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.
A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the site and will last for longer.
All cookies used on our site are set by us.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site.
Our cookies will be used for:
Essential session management
creating a specific log-in session for a user of the site in order that the site remembers that a user is logged in and that their page requests are delivered in an effective, secure and consistent manner;
recognising when a user of the site has visited before allowing us to identify the number of unique users we receive to the site and make sure we have enough capacity for the number of users that we get;
recognising if a visitor to the site is registered with us in any way;
we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our site.
customising elements of the promotional layout and/or content of the pages of the site.
Performance and measurement
collecting statistical information about how our users use the site so that we can improve the site and learn which parts are most popular to users.
5.How we use what we collect
We use information about you to:
· Present site content effectively to you.
· Provide information, products and services that you request, or (with your consent) which we think may interest you.
· Carry out our contracts with you.
· Allow you to use our interactive services if you want to.
· Tell you our charges.
· Tell you about other goods and services that might interest you. We will also let other people do this, and we (or they) may contact you.
If you are already our customer, we will only contact you electronically about things similar to what was previously contacted us about.
If you are a new customer, you will only be contacted if you agree to it.
Please note: We don’t identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.
In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at firstname.lastname@example.org and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
6.Where we store your data
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA by staff who work for us or for one of our suppliers to undertake your requested work, processing your payment details and or the provision of support services.
If we give you a password, you must keep it confidential. Please don’t share it. We will use all reasonable efforts to safeguard your personal information. However, you should be aware that we cannot guarantee the security or integrity of any personal information particularly information which is transferred from you or to you via the Internet.
We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 6 years after the date it is no longer needed by us. The only exceptions to this are where:-
· The law requires us to hold your personal information for a longer period or delete it sooner;
· You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
· We bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have been concluded and no further appeals are possible; or
· In limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
7.Disclosing your information
We are allowed to disclose your information in the following cases:
· If we want to sell our business, or our company, we can disclose it to the potential buyer.
· We can disclose it to other businesses in our group and any companies we contract to undertake work for instance claims vetting.
· We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
· We can exchange information with others to protect against fraud or credit risks.
We may contract with other third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing and processing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:
Business Banking, Accountants, IT Companies, Fraud Prevention Services.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
At present we do not pass any information onto any 3rd party marketing companies.
Under the GDPR, you have the right to:
· request access to, deletion of or correction of, your personal data held by us at no cost to you;
· request that your personal data be transferred to another person (data portability);
· be informed of what data processing is taking place;
· restrict processing;
· to object to processing of your personal data; and
· complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling as set out in section 11 below.
9.Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We advise you to check the privacy policies of any such websites if you are in doubt.
11. Automated Decision-Making and Profiling
11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant) effect on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
11.2 The right described in section 11.1 does not apply in the following circumstances:
a) the decision is necessary for the entry into, or performance of, a contract between the you and us;
b) the decision is authorised by law; or
c) you have given you explicit consent.
11.3 Where we use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.