DATA PROTECTION POLICY
|GDPR||means the General Data Protection Regulation.|
|Responsible Person||Appointed Data Protection Trustee Representative Empathpreneurs®|
|Register of Systems||means a register of all systems or contexts in which personal data is processed by Empathpreneurs®|
- DATA PROTECTION PRINCIPLES
Empathpreneurs® is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- Processed lawfully, fairly and in a transparent manner in relation to individuals;
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
- WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Datamay include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Datamay include your billing address, delivery address, email address and telephone numbers.
- Financial Datamay include your bank account and payment card details.
- Transaction Datamay include details about payments between us and other details of purchases made by you.
- Technical Datamay include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
- HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
- Direct interactions:You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- order our products or services;
- create an account on our site;
- subscribe to our service or publications;
- request resources or marketing be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give us feedback.
- Third parties or publicly available sources:We may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU.
- Calendar and meeting scheduling services such as Zoom and Calendly based outside the EU.
- GENERAL PROVISIONS
- This policy applies to all personal data processed by Empathpreneurs®.
- The Responsible Person shall take responsibility for Empathpreneurs®’ ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- LAWFUL, FAIR AND TRANSPARENT PROCESSING
- To ensure its processing of data is lawful, fair and transparent, Empathpreneurs® shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to Empathpreneurs® shall be dealt with in a timely manner.
- LAWFUL PURPOSES
- All data processed by Empathpreneurs® must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- Empathpreneurs® shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Empathpreneurs®’
- DATA MINIMISATION
- Empathpreneurs® shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Empathpreneurs® shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
- ARCHIVING / REMOVAL
- To ensure that personal data is kept for no longer than necessary, Empathpreneurs® shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- Empathpreneurs® shall ensure that personal data is stored securely using modern software that is kept up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
Empathpreneurs® takes your privacy seriously and will only use your personal information to administer any treatment you have requested or to send you relevant information via emails and newsletters. We will not share your data with any third parties*
* Analytics information:
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Empathpreneurs® shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
END OF POLICY