PRIVACY POLICY
1. WHAT IS THE PURPOSE OF THIS DOCUMENT?
1.1. CambsArt (“we/us/our”) IS committed to protecting and respecting the privacy and security of your personal information.
1.2. This Privacy Notice sets out the basis on which we collect and use personal information about you during and after your relationship with us in accordance with the General Data Protection Regulation (GDPR).
1.3. CambsArt is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
1.4. This notice applies to current and former clients / customers. This notice does not form part of any contract we may have with you. We may update this notice at any time so please check back from time to time to ensure that you have up to date information available to you.
1.5. It is important that you read this notice carefully so that you are aware of how and why we are using such information.
2. DATA PROTECTION PRINCIPLES
2.1 We will comply with data protection law. This says that the personal information we hold about you must be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.
3. INFORMATION WE COLLECT FROM YOU
3.1Personal 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).
3.2 We will collect and process the following categories of personal data about you:
Personal contact details such as name, title, address, telephone numbers and personal email / IP address
Date of birth
Gender
CCTV footage from our reception security camera
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
4.1 We collect personal information about our clients / customers and others in the following ways:
Information you give us by becoming a member, filling in forms on our Website or by corresponding with us by telephone, email or otherwise. This includes information you provide when you register to use our Website, create an account with us or book a class;
From third party data providers;
When you visit our Website we may automatically collect the following information :
technical information, including but not limited to the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, browser plug-in types and versions, operating system and platform;
information about your visit using Google Analytics or any other web analytics service, including without limitation the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), classes or pages on the Website that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
5 HOW WE WILL USE INFORMATION ABOUT YOU
5.1 We will only use your personal information when the law allows us to. Most commonly, we use information held about you in the following ways:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
where we need to comply with a legal obligation;
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;
to provide you with information about other goods and services we offer that are similar to those that you have already used, purchased or enquired about;
We may also use your personal information in the following situations, which are likely to be rare:
Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest, or for official purposes.
In particular, the situations in which we will use your personal information may include:
Administering the contract we have with you;
Business management and planning, including accounting and auditing;
To contact you from time to time about classes, products, promotions, events or other services or information that we think may be of interest to you;
To send you marketing information from time to time. We will only contact you with information about our products and services which we think will be of interest to you. You have the right to object to us sending you this information at any time (please see below);
Dealing with any legal disputes with you;
To comply with our legal obligations such as Health and Safety requirements;
To monitor your use of our information and communication systems to ensure compliance with our IT policies[3] ;
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;
To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, Google Analytics or similar;
To allow you to participate in interactive features of our service, when you choose to do so.
6. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as delivering goods or services to you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our customers / clients).
7. CHANGE OF PURPOSE
7.1 We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
7.2 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. DATA SHARING
8.1 We may have to share your data with third parties, including third-party service providers (such as IT service providers) [and other entities in the group of companies to which we belong.
8.2 We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
8.3 We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
8.4 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and/or any other agreements with you; or to protect the rights, property, or safety of CambsArt, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
8.5 Our third-party service providers [and other entities in the group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
8.6 Selected third parties including:
analytics and search engine providers that assist us in the improvement and optimisation of our Website;
credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
9. WHERE WE STORE YOUR PERSONAL DATA
9.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). If that is the case, it will be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy and Cookies Policy.
9.2 Alternatively, all information you provide to us will be stored on our secure servers. Any payment transactions will be processed and kept secure by our carefully chosen third party service provider.
9.3 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
9.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10 DATA SECURITY
10.1 We have put in place measures to protect the security of your information.
10.2 Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
10.3 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
10.4 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
11 DATA RETENTION
11.1 How long will you use my information for?
11.1.1 We will only retain your personal information 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.
11.1.2 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.
11.1.3 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
11.1.4 We will retain and securely destroy your personal information in accordance with applicable laws and regulations.
12 RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
12.1 Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your contractual relationship with us.
12.2 Your rights in connection with personal information
12.2.1 Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact info@cambsart.com
12.3 No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
12.4 What we may need from you
12.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
12.6 Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
13 CHANGES TO OUR PRIVACY POLICY
We reserve the right to update this privacy notice at any time. In the event we make substantial updates, we will make available our updated privacy notice on our website. We may also notify you in other ways from time to time about the processing of your personal information.
Contact
If you have any queries about this Privacy Notice, please email info@cambsart.com