Open Newtown understands that your privacy is important to you and that you care about how your personal data is used. [We] respect and value the privacy of everyone who visits this website, www.opennewtown.org.uk Our site will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and|
|[“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]|
[Our] Site is [owned and] operated by Going Green for A Living Community Land Trust Ltd, a limited company [registered in England under company number 10976887].
[Registered address: 9 Board Street Newtown Powys SY16 2LU]
[VAT number. 294751271]
[Data Protection Officer: Sabrina Cadman Open Newtown
Email address: email@example.com
Telephone number: 01686 610777.
Postal address: 9 Board Street Newtown Powys SY16 2LU]
[[We are] regulated by FCA.]
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which [we] will always work to uphold:
For more information about [our] use of your personal data or exercising your rights as outlined above, please contact [us] using the details provided in Part 15.
It is important that your personal data is kept accurate and up to date. If any of the personal data [we] hold about you changes, please keep [us] informed as long as [we] have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about [our] use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. [We] would welcome the opportunity to resolve your concerns [ourselves] however, so please contact [us] in the first instance, using the details in Part 15.
|Data Collected||How [We] OR [I] Collect the Data|
|[Contact information including your Title, Name, Address, telephone number, mobile telephone number and email address.]||Via our website, e-mail and phone depending on how you contact us.|
|Credit or debit card details for purchases of ticketed workshops or events.||Via our website or over the telephone|
|[Data from third parties including Your interest’s, preferences.]||Via Website and surveys collected through survey Monkey /Mail Chimp.|
Under the Data Protection Legislation, [we] must always have a lawful basis for using personal data. The following table describes how [we] [will] OR [may] use your personal data, and [our] lawful bases for doing so:
|What [We] OR [I] Do||What Data [We] OR [I] Use||[Our] OR [My] Lawful Basis|
|To respond to enquiries via our Website /social media platforms.||We need your name, email address, contact details.
We need your contact details so that we can respond to your enquiry
|To send Marketing information by e-mail, Monkey Survey or Mail chimp||We would like to send you occasional marketing information by e-mail and will only do this with your consent.||
|To collate and gather data via surveys to help Open Newtown deliver on any of its projects (Present or future)||Name, Address, Email address, telephone numbers, specific interests||
|To contact you by telephone||We would like to keep in touch with you in the future about future events. We will not do this if you do not consent to telephone contact.||
|If any payment details are taken over the telephone, then these will be destroyed at the end of the transaction.||Payment information including your cards registered address, expiry date and security code||
|For Market research purposes, to ensure the website, our products and services meet user’s needs.
To keep Visitors to our website updated about our services.
|Cookies, your device type, IP address and location data if you choose to share it with us. Any such data that is personalised to you is held for no more than 36 months before being destroyed.||
|To show you Going Green for A Living Ltd adverts and partnerships over the internet||Cookies your device type, IP address and location data if you choose to share it with us.||Legitimate Interest|
|[ By suppling you with information via [email] AND [post] that you have opted-in-to (you may opt-out at any time) by contacting Open Newtown at firstname.lastname@example.org]||Cookies, your device type, IP address and location data if you choose to share it with us. Any such data that is personalised to you is held for no more than 36 months before being destroyed.||
|To protect our website
To prevent misuse of our website and to protect the customer data that we hold.
To identify and prevent fraud.
Cookies, your device type, IP address and location data if you choose to share it with us. Any such data that is personalised to you is held for no more than 36 months before being destroyed.
[With your permission and/or where permitted by law, [we] may also use your personal data for marketing purposes, which may include contacting you by [email] AND [telephone] AND [text message] AND [post] with information, news, and offers on [our] [products] OR [services]. You will not be sent any unlawful marketing or spam. [We] will always work to fully protect your rights and comply with [our] obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.] [[We] will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.]
Third Parties (including Facebook and Google Analytics) whose content may appear on [Our] Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that [we] do not control the activities of such third parties, nor the data that they collect and use themselves, and [we] advise you to check the privacy policies of any such third parties.
[[We] use the following automated system[s] for carrying out certain kinds of [decision-making] AND/OR [profiling]. If at any point you wish to query any action that [we] take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact [us] to find out more using the details in Part 15.
[We] will only use your personal data for the purpose(s) for which it was originally collected unless [we] reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If [we] do use your personal data in this way and you wish [us] to explain how the new purpose is compatible with the original, please contact [us] using the details in Part 15.
If [we] need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, [we] will inform you and explain the legal basis which allows [us] to do so.
In some circumstances, where permitted or required by law, [we] may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
[We] will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long [We] OR [I] Keep It|
|[Identity Information including name and title||36 months|
|[Contact information including Address, email address and telephone number||36 months|
|[Business information including Business names addresses and contact details||36 months|
|[Payment information including card details||Card details are not held by Going Green for A Living Community Land Trust (Open Newtown)|
|[Profile information including any purchase information||36 months|
|[Technical information including IP address||36 months|
[[We] will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
[[We] OR [I] will [only store or transfer your personal data] OR [store or transfer some of your personal data] within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
The security of your personal data is essential to [us], and to protect your data, [we] take a number of important measures, including the following:
[[We] may sometimes contract with the following third parties to supply certain [products] AND/OR [services].
|Recipient||Activity Carried Out||Sector||Location|
|Facebook and Instagram and Twitter||Communicating with Visitors/Customers||UK|
|[Google Analytics||Analysing activity on website||UK|
If any of your personal data is shared with a third party, as described above, [we] will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, [our] obligations, and the third party’s obligations under the law, as described above in Part 9.]
[If any personal data is transferred outside of the EEA, [we] will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.]
In some limited circumstances, [we] may be legally required to share certain personal data, which might include yours, if [we are] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
You may access [certain areas of] [Our] Site without providing any personal data at all. [However, to use all features and functions available on [Our] Site you may be required to submit or allow for the collection of certain data.]
If you want to know what personal data [we] have about you, you can ask [us] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] administrative costs in responding.
[We] will respond to your subject access request within one month of receiving it. Normally, [we] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] receive your request. You will be kept fully informed of [our] progress.
To contact [us] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com
Telephone number: 01686 610777
Postal Address: 9 Board Street Newtown Powys SY16 2UL
[We] may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if [we] change [our] business in a way that affects personal data protection.
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