Website Privacy Policy – Henrik’s Troopers
CONTENTS
____________________________________________________________
CLAUSE
1. Important information and who we are......................................... 2
2. The types of personal data we collect about you......................... 3
3. How is your personal data collected?........................................... 4
4. How we use your personal data................................................... 4
5. Disclosures of your personal data................................................ 8
6. International transfers................................................................... 9
7. Data security............................................................................... 11
8. Data retention.............................................................................. 11
9. Your legal rights.......................................................................... 11
10. Contact details......................................................................... 13
11. Complaints............................................................................... 14
12. Changes to the privacy policy and your duty to inform us of changes.............................................................................................. 14
13. Third-party links....................................................................... 14
Introduction
PRIVACY POLICY
This privacy policy sets out how Henrik’s Troopers uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
3. HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
4. HOW WE USE YOUR PERSONAL DATA (paragraph 4)
5. DISCLOSURES OF YOUR PERSONAL DATA (paragraph 5)
6. INTERNATIONAL TRANSFERS (paragraph 6)
7. DATA SECURITY (paragraph 7)
8. DATA RETENTION (paragraph 8)
9. YOUR LEGAL RIGHTS (paragraph 9)
10. CONTACT DETAILS (paragraph 10)
11. COMPLAINTS (paragraph 11)
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (paragraph 12)
13. THIRD PARTY LINKS (paragraph 13)
1. Important information and who we are
Privacy policy
This privacy policy gives you information about how Henrik’s Troopers collects and uses your personal data through your use of this website, including any data you may provide when you register with us.
Henrik’s Troopers is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the DPO using the information set out in the contact details section (paragraph 10).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
· Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services based inside the UK.
· Other organisations may (with your consent) share your personal data with us, for example if you support us through JustGiving or similar platforms;
· Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example when you make an application or if you subscribe to an email newsletter. We rely on further explicit consent for any special category or children’s category data.
· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Use Type of data Legal basis and retention period
To register you as (a) Identity Consent, having obtained your prior
a new applicant (b) Contact consent to process personal data
for this specific purpose.
For any special category data and
chilren's data, in addition further
explicit consent.
For children’s data in accordance
with the Limitation Act 1980 we will
retain this data until the 25th
anniversary of the child's birth, or if
the child dies before age 18, for 6
years from the date of death.
To process your (a) Identity (a) Consent, having obtained your
application for (b) Contact prior consent to process personal
financial support (c) Financial data for this specific purpose.
or making a (d) Transaction
donation including: (e) Marketing and
Communications For any special category data and
(a) Manage children’s data, in addition further
payments, fees and explicit consent.
charges
(b) Performance of a contract
(b) Collect and with you
recover money (c) Necessary for our
owed to us legitimate interests (to recover
debts due to us)
For children’s data in accordance
with the Limitation Act 1980 we will
retain this data until the 25th
anniversary of the child's birth, or if
the child dies before age 18, for 6
years from the date of death.
To manage our (a) Indentity (a) Consent, having obtained your
relationship with (b) Contact prior consent to process
you which will (c) Profile personal data for this specific
include: (d) Marketing and purpose
Communication
(a) Notifying you For any special category data and
about changes children's, in addition further explicit
to our terms or consent.
privacy policy
(b) Performance of a contract
(b) Dealing with with you
your requests, (c) Necessary to comply with a legal
complaints and obligation
queries (d) Necessary for our legitimate
interests (to keep our records
updated and manage our
relationship with you
For children’s data in accordance
with the Limitation Act 1980 we will
retain this data until the 25th
anniversary of the child's birth, or if
the child dies before age 18, for 6
years from the date of death.
To administer and (a) Identity (a) Necessary for our legitimate
protect our business (b) Contact interests (for running our business,
and this website (c) Technical provision of administration and
(including IT services, network security, to
troubleshooting, prevent fraud and in the context of
data analysis, a business reorganisation or group
testing, system restructuring exercise)
maintenance,
support, reporting (b) Necessary to comply with a
and hosting of data) legal obligation
To use data (a) Technical Necessary for our legitimate interest
analytics to improve (b) Usage (to define types of customers for
our website, our products and services, to keep
products/services, our website updated and relevant,
customer relationships to develop our business and to
and experiences inform our marketing strategy)
and to measure the
effectiveness of our
communications
and marketing
(a) Technical
(b) Usage
To send you (a) Indentity Consent, having obtained your
relevant marketing (b) Contact prior consent to receiving direct
communications (c) Technical marketing communications
and make (d ) Usage
personalised (e) Profile
suggestions and (f) Marketing and
recommendations Communcations
to you about goods
or services that
may be of interest
to you based on
your Profile Data
Direct marketing
During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Henrik’s Troopers via EMAIL, SMS, TELEPHONE, POST. Further you will receive marketing communications from us if you have requested information from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which information may be of interest to you so that we can then send you relevant marketing communications.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example updates to our Terms and Conditions, checking that your contact details are correct.
5. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
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 data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the UK.
7. Data security
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. 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.
8. Data retention
How long will you use my personal data for?
Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our applicants and donors (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for regulatory purposes.
For children’s data in accordance with the Limitation Act 1980 we will retain this data until the 25th anniversary of the child's birth, or if the child dies before age eighteen for six years from the date of death.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will 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.
9. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- 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
- You have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us see Contact details (paragraph 10).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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 speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
10. Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:
· Email address: hello@henrikstroopers.co.uk
11. Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
13. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
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