This privacy notice describes how Freehold CIC (which we will call ‘we’ or ‘us’) collect and process personal information about you, how we use and protect this information and your rights in relation to this information.
This privacy notice applies to all personal information we collect or process about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.
This privacy notice is effective from and including [16 November 2020]. It may vary from time to time so please check it regularly.
1. Personal information we use
We will collect personal information about you from a variety of sources, including
information we collect from you directly (e.g. when you contact us) and information we collect about you from other sources, described below.
Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of our obligations. We will inform you at the time your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.
1.1. Information we collect directly from you
a. When you visit our websites the web server collects some basic information such as your browser type, MAC or IP address, internet service provider’s domain name, which pages you accessed on the site, and when. Details of cookies that we use on our websites can be found in our Cookies Notice.
b. When you submit your request for membership we collect personal information such as your email address, name, contact number, preferred pronouns and gender identity. Not all fields are mandatory. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit this information.
c. When you leave comments on the website we collect the data shown in the comments form, and also the IP address and browser user agent string to help spam detection.
d. We use Google Analytics on our site for anonymous reporting of site usage. So, no personalized data is stored. If you would like to opt-out of Google Analytics monitoring your behaviour on our website please use this link: Google Analytics Opt-out.
e. You may be asked to complete a survey or questionnaire either directly at our events or via email, SMS or post and in doing so we may ask for details such as your age, gender and postcode. The information captured is for research purposes and so we can understand the needs of our members.
f. At our events, we take photos of our members which may be used on our website or on social media. Where we do so, we inform our members of this possibility through the signs placed around the location of the event.
g. We may record and retain details of the attendees at the events we host.
2. How we use your personal information and the basis on which we use it
We use your personal information to:
a. provide and personalise our services;
b. deal with your enquiries and requests;
c. comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
d. contact you about events hosted by Freehold or hosted in partnership with Freehold;
e. contact you with news or other information about the activities of Freehold or its members;
3. Who has access to your data
If you are not a registered member for our site, there is no personal information we can retain or view regarding yourself.
If you are a client with a registered account, your personal information can be accessed by:
a. our system administrators
b. The Freehold Board
We also contract with third parties which in certain circumstances will be processors who deal with your personal data in accordance with our instructions. Where we appoint a third party processor of your personal data we will put a framework around what we expect them to do with it and how they manage it.
4. What are your rights?
You have certain rights regarding your personal information, subject to local law. These include the following rights to:
- access your personal information
- rectify the information we hold about you
- erase your personal information
- restrict our use of your personal information
- object to our use of your personal information
- receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)
- lodge a complaint with your local data protection authority.
If you would like to exercise any of your rights, please utilise one of the methods listed in the Contact Us section
5. Information Sharing
We may share your personal information with third parties under the following circumstances:
- Law enforcement agency, court, regulator, government authority, insurer or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party or to put in place insurance for our centres and other buildings.
The recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “International Data Transfer” below for more information.
6. Information Security and Storage
We use the SSL/HTTPS protocol throughout our site. This encrypts our user communications with the servers so that personally identifiable information is not captured/hijacked by third parties without authorization.
In case of a data breach, system administrators will immediately take all needed steps to ensure system integrity, will contact affected users and will attempt to reset passwords if needed.
When you submit a support ticket or a comment, its metadata is retained until (if) you tell us to remove it. We use this data so that we can recognize you and approve your comments automatically instead of holding them for moderation.
If you register on our website, we also store the personal information you provide in your user profile. You can see, edit, or delete your personal information at any time (except changing your username). Website administrators can also see and edit that information.
7. International Data Transfer
Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law / by the European Commission. Where this is the case we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
8. Contact Us
Freehold CIC is the controller responsible for the personal information we collect and process (save in circumstances where we specify otherwise).
If you have questions or concerns regarding the way in which your personal information has been used, or would like to contact our Data Protection Officer, please contact firstname.lastname@example.org
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the United Kingdom using their website https://ico.org.uk/.
9. Changes to the Notice
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time.