1. IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy sets out how the Neighbourhood Toolbox CIC, a community interest company registered in England and Wales under company number 15480137 whose registered office is at 81 Locks Hill, Frome, England, BA11 1ND (collectively referred to as the “Company”, “NTB” “we”, “us”, or “our” in this privacy policy) is responsible in its capacity as controller, for using and protecting your personal data.
We take protection of your privacy very seriously. This privacy policy gives you information about how NTB collects and uses your personal data through your use of this website (https://neighbourhoodtoolbox.co.uk/) (the “Website”) including any data you may provide when you register to become a member of NTB, join our mailing list or participate in any of our services. Specifically, in this privacy policy, we seek to explain to you with clarity:
The types of personal information we collect about you;
- How we use the information we collect;
- How we disclose the information we collect;
- How we store the information we collect;
- How long we keep the information;
- How to access and control your information; and
- Other important privacy information.
This Website is not intended for children and we do not knowingly collect data relating to children.
Neighbourhood Toolbox Privacy Policy
2. 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:
- Identity Data which includes first name, last name, any previous names, marital status, title, date of birth and gender.
- Contact Data which includes correspondence address, email address and telephone numbers.
- Financial Data which includes bank account and payment card details.
- Transaction Data which includes details about payments to and from you.
- Technical Data which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types. and versions, operating system and platform, device ID and other technology on the devices you use to access the Website.
- Profile Data which includes your feedback and survey responses.
- Usage Data which includes information about how you interact with and use the Website.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals & usage data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with the Website to help improve the Website and our service offering.
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, attending our in-person surgery sessions/workshops or otherwise. This includes personal data you provide when you:
- subscribe to our services or publications;
- donate to us;
- become a member of NTB;
- attend our in-person workshops and events;
- request marketing to be sent to you by subscribing to our mailing list; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with the Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see further details on the cookies used in section 4 below.
Third parties. We receive personal data about you from the following third parties:
- Technical Data is collected from Monster Insights, a WordPress plugin that integrates Google Analytics into the Website.
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe Payments Europe, Ltd, a company registered in Ireland under company number IE513174, trading as Stripe based outside the UK. You may find their privacy notice here: https://stripe.com/gb/privacy.
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:
- 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 in order 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 legal obligations that we may be subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below 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.
DIRECT MARKETING
You will receive marketing communications from us if you have subscribed to our mailing list and requested information from us, became a member of NTB or applied to receive services 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 services, workshops and industry data may be of interest to you so that we can then send you relevant marketing communications.
THIRD-PARTY MARKETING
We will obtain your express consent before we share your personal data with any third party for their own direct marketing purposes.
OPTING OUT OF MARKETING
You can ask us to stop sending you marketing communications at any time by contacting us through the details contained in section 11. 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 relating to appointment/workshop reminders, updates to our Privacy Policy/Terms and Conditions and ensuring that your contact details are correct.
5. COOKIES.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer & hard drive.
We use two analytical cookies provided by Google Analytics: _ga_* and _ga. The cookies allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily. The cookies store information anonymously and assign a randomly generated number to the visitors. The cookie will last for two years.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. Please refer to Google’s privacy policy for further information https://policies.google.com/privacy?hl=en-US.
6. DISCLOSURES OF YOUR PERSONAL DATA.
We may share your personal data where necessary with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business,
then the new owners may use your personal data in the same way as set out in this privacy policy.
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.
7. INTERNATIONAL TRANSFERS.
We do not transfer your personal data outside the UK.
8. DATA SECURITY.
We have adopted 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 by employees, agents, contractors and other third parties who may require the need for such data. 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.
9. DATA RETENTION.
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 customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 10 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.
10. YOUR LEGAL RIGHTS.
You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- The absolute right to object any time to the processing of your personal data for direct marketing purposes (see section 4 for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
1. If you want us to establish the data’s accuracy;
2. Where our use of the data is unlawful but you do not want us to erase it;
3. 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
4. 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 through the contact details specified in section 11.
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.
11. 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 us in the following ways:
- Email address: hello@neighbourhoodtoolbox.co.uk
- Postal address: 81 Locks Hill, Frome, England, BA11 1ND
12. 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.
13. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on 28.10.2024. Historic versions can be obtained by contacting us.
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.
14. 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 the Website, we encourage you to read the privacy policy of every website you visit.