Policy Privacy - Champions of Mind Ltd
We are the controller of your data and are responsible for its storage and use. It is important that the personal data we have on record about you is accurate and up to date. We ask that you keep us informed as soon as possible of any personal data changes.
We may also act as a processor of your data on behalf of a data controller, in which case we are not responsible for it but the same standards of privacy will always apply.
At no time are our services intended for children and we do not knowingly collect data relating to children.
Contacting Our Data Officer & Complaints
We have appointed a data privacy officer. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using these details below:
Data Privacy Officer – James Burtt
20-22 Wenlock Road, London, N1 7GU, England
Or alternatively by email:
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. The ICO’s website can be viewed at www.ico.org.uk. We would, however, appreciate the chance to deal with any concerns before you approach the ICO, so please contact us in the first instance.
If we provide links to third-party websites, plug-ins and applications, during our relationship with you, that is not a representation that we control such third-party resources and we are not responsible for their privacy policies. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We encourage you to read the privacy policies of every website you visit.
Where we need to collect personal data by law, or under the terms of our contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contracted services we have or are trying to enter into with you. In such a case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. We accept no liability under contract if it cannot be performed due to your withholding of data from us.
Personal data means any information from which that individual/ business can be identified. We may process different kinds of personal/ company data which we have listed below as follows:
Identification Data includes first name, maiden name, last name, company name, account usernames or similar identifier.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes your password and login data, browser type and version, internet protocol (IP) address, 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 services.
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 products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data or criminal convictions and offences.
How We May Collect Data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us data by filling in website forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you, for example:
Request for our products or services;
Use of our bespoke client zone services
Subscribe to our services;
Request marketing materials to be sent to you;
Enter a competition, promotion or survey; or
Give us feedback.
WHAT IS A COOKIE?
A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Cookies are either:
– Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
– Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. At CVM Digital we use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
– Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
– Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, for example:
Analytics and search information providers;
Providers of technical, payment and delivery services;
Data brokers or aggregators;
Companies House; and
The Electoral Register;
Other Data Controllers or Processors: When our client is a data controller or data processor of your data (and so we are a processor or sub-processor, respectively), we may be provided your data in order to fulfil our contract with our client. We do not take responsibility for the privacy standards of our client, but endeavour to ensure they meet with the legal minimum. In any event, our standards of privacy will apply to your data whether we have obtained information directly from you or from a controller client.
How We Use Your Data
We will only use your personal data when the law allows us to. Most commonly, we will use your data in the following circumstances:
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.
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 or regulatory obligation.
By using our services, you leave certain information with us. This could be personal data. We only keep and use the data provided by you, within the framework of the service you request, or when it is clear, that they are provided to us to process.
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
We may also use your information to contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.
We do not publish your data unless express permission has been granted.
Sharing Your Data
If you are a client who uses our services, we use your personal data for the processing thereof. If necessary for further processing, we may also provide your personal data to third parties, such as companies we work with to fulfil your requirements.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom, who provide consultancy, banking, legal, insurance and accounting services.
Service providers acting as processors who provide IT and system administration services.
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third-party email marketing providers (only where campaigns have been requested)
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/ company data for their own purposes and only permit them to process your data for specified purposes and in accordance with our instructions.
Once it is within our control, we do not transfer your personal data outside the European Economic Area (‘EEA’), unless you (or the third party controller or processor which is instructing us and to which you have given your data which we are then processing) are based outside the EEA.
Data Security & Retention
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. As above, 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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and contractual legal limitation purposes.
In some circumstances we may 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. 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 overrides 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under such circumstances.
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 hasten our response.
We try to respond to all legitimate requests within one month. Occasionally it may 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.