We, Freehold CIC (we, us or Freehold) are committed to protecting the privacy of all those whose personal data we process. Please read the following privacy policy that explains how we use and protect your information.
You may be reading this privacy policy for a range of reasons, for instance, you may be (i) a visitor to freeholdlgbt.com (our website); (ii) a member of Freehold; (iii) a director of Freehold; (iv) an employee of a Freehold sponsor; (v) supporters and charities; (vi) event attendees; (vii) an employee or director of a pro bono or paid supplier to Freehold; or (viii) another third party Freehold contact.
Paragraphs 1 to 11 of this policy apply to you, whichever category you fall into. Also note that specific information in relation to our use of your personal information can be found here:
Freehold is the data controller of all personal information that we process about you.
CONTACT DETAILS
If you have any queries or requests concerning this privacy policy or how we handle your personal data more generally, please get in touch with us by contacting us at info@freeholdlgbt.com.
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information if: you have provided your consent; we are under a legal obligation to do so; or we have a legitimate interest for processing your data.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 11 below.
The personal information we are holding about you may, on the legal grounds set out in this privacy policy, be shared with and processed by:
Where we have a legitimate interest for doing so (and are permitted to do so by law) we will use your information to let you know about our other events and opportunities and we may contact you to do so by email. You can withdraw your consent or opt out of receiving our marketing communications at any time. You may opt-out of receiving marketing communications and updates at any time by clicking on the “unsubscribe” link located at the bottom of Freehold emails, or by emailing info@freeholdlgbt.com and request to be removed from the mailing list. NB: if you are removed from the mailing list, you will no longer receive invites to Freehold events.
You can update your contact details on our mailing list by clicking the “update your preferences” link on the bottom of Freehold emails, or by emailing info@freehold.lgbt.com.
We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.
We take appropriate technical and organisational measures to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
This privacy policy does not apply to information processed by third parties, including event host organisations and event management and ticketing providers.
Our website may contain links to third parties which we do not own or control – this privacy policy does not apply to these third-party websites that are accessible from, or referenced on, our website. We are not responsible for the privacy policies of other websites, and encourage you to read all applicable terms, conditions and privacy polices when using other websites.
We will not retain your information for any longer than we think is necessary.
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in paragraph 3.
When determining the relevant retention periods, we will take into account factors including:
Otherwise as a general rule, we securely erase your information (to the extent legally and technically practicable) where we no longer require your information for the purposes collected. We will keep basic data to identify you and retain it solely for preventing further unwanted processing. Unless we are required or permitted by law to hold on to your information for a specific retention period, we may retain your information for the following purposes and periods:
Under data protection law, you have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact us at info@freeholdlgbt.com. For additional information on your rights please contact your data protection authority and see below.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
The right of access. You have the right to request certain information about, access to and copies of your personal information (if we’re processing it).
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you. However, please note that this will not apply if we are required to retain the information for compliance with a legal obligation.
The right to restrict processing. You have rights to request that we stop using your personal information or limit the way in which we use it. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to request that we return your personal information in an accessible and transferrable format, or that we send it directly to another company, where technically feasible.
The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection authority. If you are in the UK, this is the ICO – https://ico.org.uk. The postal address is Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. where we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time. Please note that this may impact our ability to provide information and invitations to future Freehold events and activities and other membership services.
The right to object to processing. You have the right to object to certain types of processing where we use it for our legitimate interests or for marketing purposes.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
Any changes to our privacy policy will be posted to our website and, where appropriate, we may notify you of the changes for example by email. This privacy policy was last updated on 13 November 2023.
ANY VISITOR TO OUR WEBSITE
We collect information when you:
Some of the information is collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies which are active on our website. These cookies help us to provide you with a good experience when you are browsing, and also help us to improve our website. For more information on cookies and what you can do to disable certain cookies on our website, please read our Cookie Policy
It is in our legitimate business interests to do so: to monitor and perform analytics in respect of who is visiting our website; to consider and respond to your message or request; or if you are a subscriber to our newsletters, or other communications, to tailor marketing communications to your needs and preferences.
Consent: where we have requested your consent and you have provided it.
FREEHOLD MEMBERS
(INCLUDING PROSPECTIVE OR FORMER MEMBERS)
We collect the following information about you:
We collect information when you:
It is in our legitimate business interests to do so: to keep internal records for administration purposes; to monitor the demographic of our membership to personalise and improve our platform (e.g. so you receive our newsletters and event invites quicker); to enable us to help you with any enquiries or questions in the most efficient way possible; to contact you for your views and feedback on our events and activities, to administer our mentoring programme (if you have opted in to be a mentor or mentee), to notify you if there are any important changes or developments within Freehold; to find potential speakers at Freehold events or contributors to Freehold articles; to analyse your engagement with Freehold so that we can administer, support, improve and develop our operations; to develop our marketing or advertising materials; to enable us to deliver tailored communications to you, to present you with new opportunities and ways to engage with us.
Consent: where we have requested your explicit consent in relation to your sexual orientation, ethnic origin and health, and you have provided it.
In addition to the parties set out in paragraph 4 at the front of this privacy policy, the personal information we are holding about you may, on the legal grounds set out in this privacy policy, be shared with and processed by the Freehold LGBT+ CIC Board of Directors, our administrative service provider that review all membership applications and our service providers.
FFREEHOLD DIRECTORS
We collect the following information about you:
We collect information when you volunteer for a directorship role on the Freehold board.
It is in our legitimate business interests to do so: for promoting our business; to contact you (and other individuals) and to defend legal claims or otherwise protect our rights as a business.
Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.
EMPLOYEES OF OUR SPONSORS
We collect the following information about you:
We collect information provided to us by your employer who is sponsoring Freehold CIC, providing pro-bono services to us or sponsoring an event or activity.
It is in our legitimate business interests to do so: to tailor marketing and communications to your needs and preferences.
SUPPORTERS AND CHARITIES
We collect the following information about you:
We collect information when we contact you to organise or participate in our events.
It is in our legitimate business interests to do so: to tailor marketing and communications to your needs and preferences.
SUPPORTERS AND CHARITIES
We collect the following information about you:
We collect information when we contact you to organise or participate in our events.
It is in our legitimate business interests to do so: to tailor marketing and communications to your needs and preferences.
EVENT ATTENDEES
We collect the following information about you:
We collect information when you register to attend or attend our events. 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 some of the details listed above.
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.
It is in our legitimate business interests to do so: to tailor marketing and communications to your needs and preferences for our events; and for research purposes so that we can understand the needs of our members.
In addition to the parties set out in paragraph 4 of the front of this privacy policy, personal information we are holding about you may on the legal grounds set out in this privacy policy be shared with our service providers including event management and ticketing providers to produce guest lists and name badges.
OTHER THIRD PARTY FREEHOLD CONTACTS
We collect the following information about you:
We collect information when we contact you to organise or participate in our events.
It is in our legitimate business interests to do so: to tailor marketing and communications to your needs and preferences for our events.
